Group health plans are entering 2026 amid rising complexity, as regulatory shifts, legal challenges, and evolving expectations drive new considerations for employer-sponsored plans.
Blog
April 23, 2026
Group health plans are entering 2026 amid increasing complexity. Regulatory changes, legal challenges, and evolving coverage expectations are converging and driving new compliance risks.
From prescription drug transparency to reproductive health laws and wellness program scrutiny, employer-sponsors may want to review how they evaluate, document, and support plan-related decisions.
Here’s what to watch in 2026. If you want to take a deeper dive, read our full Report.
Why 2026 Requires a Different Approach
What sets 2026 apart is the convergence of several evolving issues.
Key areas that are evolving at the same time include:
- Prescription drug costs and PBM oversight
- Gender-affirming care coverage
- Reproductive health coverage
- Preventive services requirements
- Wellness program design and tax structures
Individually, each requires attention. Together, they create ongoing compliance challenges.
View the full report for a deeper look at how these five areas intersect and what that may mean for plan sponsors.
Prescription Drug Costs: Transparency Changes the Equation
New transparency requirements are increasing visibility into PBM practices while also raising expectations for plan sponsors.
It may no longer be enough to receive reports. Employer-sponsors may want to actively review and understand them, with documented oversight.
View the full report for plan sponsor action steps on evaluating PBM data and strengthening oversight processes.
Gender-Affirming Care: An Evolving Legal Landscape
Coverage decisions in certain areas are becoming more nuanced.
Plan sponsors may need to navigate:
- Differing state laws
- Ongoing litigation
- Federal compliance considerations
These decisions can carry risk beyond plan design, especially as legal interpretations continue to evolve.
View the full report for considerations around coverage design, legal developments, and alternative approaches.
The result is a balancing act among compliance, flexibility, and employee expectations.
The result is a balancing act among compliance, flexibility, and employee expectations.
Reproductive Health Coverage: Navigating State-by-State Differences
State-by-state variation continues to create challenges, particularly for multi-state employers.
At the same time, growing attention on fertility and infertility coverage is introducing new decision points.
The result is a balancing act among compliance, flexibility, and employee expectations.
View the full report for strategies to help address multi-state complexity and potential coverage gaps.
Preventive Services: Stable, but Evolving
The preventive services mandate remains in place, but what qualifies as “preventive” may change over time based on federal guidance.
This creates a need for ongoing monitoring, not just periodic review.
View the full report for what to watch and how changes to preventive care guidance may impact your plan.
Wellness Programs: Increasing Scrutiny
Wellness programs remain valuable—but are facing increased legal scrutiny.
In particular:
- Tobacco surcharge programs are being challenged
- Certain tax-advantaged arrangements are under regulatory scrutiny
Small design decisions could carry potential compliance implications.
View the full report for key considerations when evaluating wellness program structure and compliance risk.
The Bigger Shift to Active Oversight
Across all of these areas, expectations for plan sponsors appear to be increasing.
Compliance may be shifting toward demonstrating:
- Ongoing review
- Thoughtful decision-making
- Clear documentation
Employer-sponsors who take a more proactive, structured approach may be better positioned to navigate the year ahead.
Get the Full Breakdown
This overview highlights key trends. Inside the full report, you’ll find insights on how you can:
- Navigate new PBM reporting requirements and fiduciary considerations
- Evaluate coverage approaches for gender-affirming & reproductive care
- Monitor preventive services updates following the Kennedy v. Braidwood decision
- Review wellness & tobacco surcharge program design considerations in light of applicable requirements
Download the full report: Critical Employee Benefits Updates in 2026: Group Health Plans
The information here is for general informational purposes only; employers should consult their qualified advisors when evaluating plan design or compliance decisions.
Insights
