At 2 a.m. on Sunday, Nov. 2, it wasn’t just the end of daylight savings time and the clocks rolling back one hour, but it was the unofficial countdown to the end of the year for business owners.
November and December quickly become a blur of holidays, travel, and fiscal deadlines, all unfolding as the days figuratively and literally grow shorter, with the winter solstice arriving on Sunday, Dec. 21, the shortest day of the year.
By this point, employers only have a limited number of working days left to finalize employee benefits. Staying ahead of annual deadlines and regulatory updates is essential to avoid penalties and ensure employees maintain uninterrupted access to the coverage and protections they depend on.
“Wrapping up end-of-the-year tasks is no small feat – so the month of December can feel like a mad rush for HR pros,” wrote Carol Warner in HR Morning.
Whether your business has expanded, entered new markets, or added more variable-hour workers this year, now is the ideal time to make sure your benefit plans, notices, filings, and contribution limits are aligned with 2025 requirements. Use this employer-friendly compliance guide to close out the year with clarity and confidence.
The Affordable Care Act (ACA) remains the foundation for employer benefit compliance, particularly for Applicable Large Employers (ALEs). A few requirements shift annually, and 2025 brings several important updates.
Each year, the IRS adjusts benefit plan limits. Here are the finalized 2025 numbers.
Minimum deductibles for 2025:
Out-of-pocket maximums:
2025 HSA contribution limits:
2025 FSA updates:
Employers offering carryovers or grace periods should verify which design applies and update plan documents accordingly.
The IRS continues to enforce strict FSA substantiation rules:
Plans failing to comply risk disqualification, which creates tax issues for both employers and employees.
Under the ACA’s preventive care rules, non-grandfathered plans must continue covering employees at no cost: immunizations recommended by the Advisory Committee on Immunization Practices (ACIP).
Routine vaccines covered include:
COVID-19 is now treated like any other ACIP-recommended immunization; dedicated COVID sections are no longer needed.
Most employer-sponsored health plans require annual distribution of specific notices. Review your calendar to confirm these have been sent or are scheduled.
Common required notices include:
Notices can be distributed electronically if certain requirements are met. Some notices (COBRA, SPD) may not be strictly annual but occur at key events or periodic intervals.
The Consolidated Appropriations Act (CAA) has shifted employer responsibilities significantly over the past two years. Several elements continue to carry strict enforcement:
Prescription Drug Data Collection (RxDC Reporting)
Transparency in Coverage (TiC) Rules
Compliance Focus for 2025
The Mental Health Parity and Addiction Equity Act (MHPAEA) continues to be a top audit area. Employers should ensure:
DOL audits are increasing, making this an essential year-end review item.
Telehealth & Virtual Care Considerations
Temporary pandemic-related telehealth flexibilities have expired. Employers with HDHP plans must ensure:
| Category | Key Actions for Employers |
| ACA Requirements | • Confirm ALE status for 2025 • Check affordability (8.33%) • Update plan offerings for minimum value & essential coverage • Prepare 1094/1095 filings (Employee copies: March 2, 2026; IRS: March 31, 2026) |
| Plan Limits & Contributions | • Apply 2025 OOP max limits (non-HDHP: $9,650/$19,300) • Update HDHP deductibles & OOP max • Adjust HSA contributions ($4,300/$8,550) • Confirm 2025 FSA limits ($3,200) & carryover ($640) |
| FSA/HSA Compliance | • Implement strict substantiation requirements • Update SPD and plan documents • Communicate contribution changes to employees |
| Annual Notices | • SBC • SPD • HIPAA notices • CHIP notice • Medicare Part D notice (prior to Oct. 15 each year) • COBRA initial notice • Surprise Billing notice • WHCRA notice |
| CAA/Transparency | • Confirm RxDC reporting (due June 1 each year) • Submit gag clause attestation • Ensure MRFs remain publicly posted |
| Mental Health Parity |
• Complete NQTL analysis |
| Telehealth & Virtual Care | • Confirm HDHP compatibility rules • Update plan language for telehealth benefits • Coordinate with carriers/TPAs for accurate SPD and compliance |
Navigating employee benefits, reporting rules, and evolving compliance requirements can be overwhelming this time of year. Dean & Draper is here to guide you through every step, from ACA filings to plan design updates to annual notices.
Contact Dean & Draper today to schedule your 2025 year-end benefits review and stay ahead of compliance with confidence.
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