Small Business Benefits
Consolidated Appropriations Act, 2021, including the No Surprises Act; The Transparency in Coverage Rule; and the Inflation Reduction Act of 2022
Federal laws have introduced changes that impact most employer-sponsored, self-funded health benefit plans:
We will keep brokers updated on important provisions; help plans administered by Star Marketing and Administration, Inc. comply with applicable aspects; and educate members about changes.
A timeline for provisions follows for self-funded ERISA plans.
- The Consolidated Appropriations Act, 20211, including the No Surprises Act2, ushered in new federal mandates, such as those designed to prevent surprise medical bills.
- As provisions in the Transparency in Coverage Rule3 made healthcare price information publicly accessible, consumers gained even more information to make informed healthcare decisions.
- Due to Medicare Part D changes required by the Inflation Reduction Act of 2022, some health benefit plans that previously were considered creditable will be non-creditable in 2025.
We will keep brokers updated on important provisions; help plans administered by Star Marketing and Administration, Inc. comply with applicable aspects; and educate members about changes.
A timeline for provisions follows for self-funded ERISA plans.
Medicare Part D Changes for 2026: What Employers Need to Know
9/30/2025
Starting January 1, 2026, Medicare Part D will cap annual out-of-pocket prescription drug costs at $2,100 (up from the $2,000 cap set for 2025).1
Why It Matters:
This change could cause some employer-sponsored prescription drug plans that were previously “creditable” to now be classified as non-creditable. Creditable coverage means your plan’s prescription drug benefits are expected to pay, on average, as much or more than Medicare Part D.
Reminder:
Employers must notify Medicare-eligible employees every year whether their prescription coverage is creditable or not. If notices aren’t sent, employees could face penalties for late Medicare Part D enrollment—and employers risk compliance issues.
What You Need to Do:
If you offer a group health plan administered by Star Marketing and Administration, Inc.:
- Log in at TrustmarkSB.com/login
- Open your Administration Kit
- Use the 2026 Medicare Calculator to check your plan’s creditable status
- Review results now to confirm compliance and send notices before Oct. 15, 2025, if required
If Your Plan Is Non-Creditable:
You Are Required to:
- Notify all Medicare-eligible members 60 days prior to the plan start date
- Provide CMS required notices
- Understand that failure to act may result in penalties and compliance exposure
2026 ACA Cost-Sharing and High-Deductible Health Plan Limits
8/26/2025
A non-grandfathered group health plan’s in-network out-of-pocket maximum for essential health benefits (EHBs) for the 2026 plan year cannot exceed $10,600 for self-only coverage and $21,200 for other-than self-only coverage.
The in-network out-of-pocket maximum applies to all individuals, regardless of whether an individual has a self-only plan or other-than single coverage. Self-funded group health plans are not required to cover EHBs. But, if they do, they cannot impose lifetime or annual dollar limits on those benefits.
For high-deductible health plans (HDHPs) for the 2026 plan year, the out-of-pocket limit will be $8,500 for self-only coverage and $17,000 for other-than self-only coverage. The minimum deductible is changing to $1,700 for self-only coverage and $3,400 for other-than self-only coverage.
Data to be Requested to Meet Federal Mandate
3/17/2025
The Consolidated Appropriations Act, 2021, requires the submission of certain data by June 1, 2025, for the Prescription Drug Data Collection (RxDC) report. The data will show spending on prescription drugs and healthcare services, prescription drugs that account for the most spending, drugs that are prescribed most frequently, prescription drug rebates from drug manufacturers, the required contribution for each employer-sponsored plan in 2024 for covered employees, as well as cost-sharing for covered employees.
We submit data annually for each group. Today, we sent an email to sponsors of self-funded health benefit plans requesting information that is needed to complete the submission accurately. The deadline for employers to submit the information is March 28, 2025.
The Consolidated Appropriations Act, 2021, requires the submission of certain data by June 1, 2025, for the Prescription Drug Data Collection (RxDC) report. The data will show spending on prescription drugs and healthcare services, prescription drugs that account for the most spending, drugs that are prescribed most frequently, prescription drug rebates from drug manufacturers, the required contribution for each employer-sponsored plan in 2024 for covered employees, as well as cost-sharing for covered employees.
We submit data annually for each group. Today, we sent an email to sponsors of self-funded health benefit plans requesting information that is needed to complete the submission accurately. The deadline for employers to submit the information is March 28, 2025.
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Machine-Readable Files
1 The Consolidated Appropriations Act, 2021 was signed into law on Dec. 27, 2020.
2The No Surprises Act is part of the Consolidated Appropriations Act, 2021. The No Surprises Act does not apply to health reimbursement arrangements (HRAs) or other account-based group health plans, short-term, limited-duration insurance, and retiree-only plans.
3 The Transparency in Coverage rule was released on Oct. 29, 2020, by the U.S. Department of Health and Human Services, the Department of Labor, and the Department of the Treasury. The rule does not apply to health reimbursement arrangements (HRAs) or other account-based group health plans, short-term, limited-duration insurance, grandfathered plans, and retiree-only plans.
4 Important Open Negotiation and Independent Dispute Resolutions Deadlines
5 The following providers cannot provide notice and consent and their services are subject to the No Surprises Act: radiologists, anesthesiologists, pathologists, neonatologists, assistant surgeons, hospitalists and intensivists. In the case of an emergency, notice may be provided after a patient is stabilized. If notice and consent is not issued/obtained, protections of the No Surprises Act continue to apply.
1 The Consolidated Appropriations Act, 2021 was signed into law on Dec. 27, 2020.
2The No Surprises Act is part of the Consolidated Appropriations Act, 2021. The No Surprises Act does not apply to health reimbursement arrangements (HRAs) or other account-based group health plans, short-term, limited-duration insurance, and retiree-only plans.
3 The Transparency in Coverage rule was released on Oct. 29, 2020, by the U.S. Department of Health and Human Services, the Department of Labor, and the Department of the Treasury. The rule does not apply to health reimbursement arrangements (HRAs) or other account-based group health plans, short-term, limited-duration insurance, grandfathered plans, and retiree-only plans.
4 Important Open Negotiation and Independent Dispute Resolutions Deadlines
5 The following providers cannot provide notice and consent and their services are subject to the No Surprises Act: radiologists, anesthesiologists, pathologists, neonatologists, assistant surgeons, hospitalists and intensivists. In the case of an emergency, notice may be provided after a patient is stabilized. If notice and consent is not issued/obtained, protections of the No Surprises Act continue to apply.
Trustmark® and Trustmark Small Business Benefits® are trademarks of Trustmark Insurance Company. All other trademarks are the property of their respective owners, which are not affiliates of Star Marketing and Administration, Inc., and Trustmark Life Insurance Company.
Plan design availability and/or coverage may vary by state. Plans are administered by Star Marketing and Administration, Inc., and stop-loss insurance and ancillary coverage are provided by Trustmark Life Insurance Company.
Plan design availability and/or coverage may vary by state. Plans are administered by Star Marketing and Administration, Inc., and stop-loss insurance and ancillary coverage are provided by Trustmark Life Insurance Company.