October 27, 2025
In response to the continuing state regulatory activity involving health plans and employer sponsored employee programs, we have attached a summary of these legislative updates.
Feel free to contact your Fedeli Group service team to address your regulatory compliance questions and concerns.
California: Worker Protections
As of October 1, 2025, California reinstated Labor Code provisions (formerly repealed) for acts or omissions that occurred on or before December 31, 2024. During the prior provision period, the Division of Labor Standards Enforcement (DLSE) managed these protection provisions. This retroactive reinstatement includes remaining protections under the California Fair Employment and Housing Act (FEHA) which will continue to be enforced by the Civil Rights Department (CRD).
The law states that employers with 25 or more employees shall provide reasonable workplace safety accommodations for employees (or their family members) who are victims of a qualifying act of violence. This may include modified schedules, workstation adjustments, additions to security measures and reasonable adjustments. Employers shall be prohibited from discriminating against or retaliating against employees who:
California: Dental Insurance
As of October 1, 2025, California health insurers and managed care plans shall provide dental providers with no-cost payment options. This effectively ends the practice of automatically defaulting to payment methods that charge fees. Dental providers will now need to actively opt in to enroll in any payment method that charges transaction fees.
Insurers must also disclose fee amounts, explain alternative payment options, and inform dentists of payment vendors who share profits or board positions with the insurer.
California: Worker Reinstatement
As of October 3, 2025, California extended the sunset date of the recall and reinstatement rights for employees laid off as a result of the COVID-19 pandemic. The new expiration date is January 1, 2027.
California: Prior Authorization
Effective October 6, 2025, California requires health insurers and managed care plans to report details about services that require prior authorization and their respective approval rates. Any services that previously had a minimum 90% approval are exempt from these reporting requirements. The California Department of Managed Health Care and the Department of Insurance shall issue reporting instructions by July 1, 2026. The requested data must then be reported before the end of the 2026 calendar year.
California: Healthcare Coverage
On October 6, 2025, California introduced technical and administrative changes to the manner that health insurance plans and health care service plans detail autism service providers. Health plans shall list qualified autism service providers in their provider directories alongside other practitioners in the plan’s network.
California: Hospital Services
On October 7, 2025, California requires hospitals to prescreen patients for participation eligibility in their charity care and discount payment policies. Eligibility requires enrollment in CalFresh or CalWORKs. The expected effective date is January 1, 2027.
California: Worker Compensation
On October 7, 2025, California is introducing penalties for contractors claiming that they do not have employees in order to avoid obtaining workers’ compensation insurance. If a contractor is found employing workers without having obtained workers’ compensation insurance, the contractors face substantial penalties. A sole proprietors shall face a fine of at least $10,000 per violation. Partnerships, corporations, and limited liability companies shall face minimum penalties of $20,000 per violation. A repeat offender may face subsequent penalties of $30,000 per occurrence.
California: Workers’ Compensation
On October 7, 2025, Bulletin 2025-15 was issued by the Workers’ Compensation Insurance Rating Bureau of California. The Bulletin announced the Quarterly Experience Report on insurer loss and premium experience valued as of June 30, 2025.
California: Pharmacy Benefit Managers (PBM)
On October 11, 2025, California introduced the following PBM regulations:
California: Prevailing Wage Credits
On October 11, 2025, California strengthened its annualization requirements governing how employers claim credit for fringe benefits when calculating prevailing wages on public works projects. Going forward, employers who seek credit for higher benefit payments on public works projects are required to calculate those credits on an annualized basis across all construction work.
California: Health Provider Credentialing
On October 11, 2025, California introduced a 90-day deadline for health plans and insurers to finalize credentialing decisions upon receipt of completed applications from healthcare providers. However, only mental health and substance use disorder providers are required to receive a response within 60 days.
California: Workers’ Compensation
On October 11, 2025, California requires parties in workers’ compensation cases to reveal in writing any financial stakes they hold in service providers.
California: Health Care Purchase
On October 11, 2025, California amended the California Health Care Quality and Affordability Act. The amendments include increased state oversight of private equity groups, hedge funds and management services organizations participating in health care transactions. These entities are required to provide a 90 days’ written notice to the Office of Health Care Affordability prior to completing transactions involving material asset transfers or governance changes with health care entities.
California: Workers’ Compensation
On October 11, 2025, California amended its Code of Civil Procedure to permit recovery of damages for a decedent’s pain, suffering or disfigurement in wrongful death cases. This change shall apply to matters filed between Jan. 1, 2022, and Jan. 1, 2026, in addition to cases granted expedited trial preferences before 2022. During this four-year pilot program period, personal representatives and heirs may now seek recovery of these previously unapproved damages. Families who had a family member whose loved ones experienced pain and suffering before passing from medical malpractice, accident, or other negligence may seek compensation.
California: Health Care Activity
On October 13, 2025, California introduced protections for healthcare providers, patients, and volunteers from experiencing legal threats related to reproductive and gender-affirming care that is lawful in California. Under the regulations, healthcare providers, employees, and volunteers may now participate in the state’s address confidentiality program. Program participants are authorized to use a state-designated address thereby shielding their home address from public records.
As of January 1, 2026, prescriptions for testosterone and mifepristone shall no longer be reported to California’s Controlled Substance Utilization Review and Evaluation System (CURES). The Department of Justice shall remove existing records of these prescriptions before January 1, 2027.
California: Health Insurance Coverage
Beginning on October 13, 2025, California will require health insurers to include coverage for comprehensive fertility services and an expansion of durable medical equipment coverage.
The comprehensive fertility services shall include:
The expanded coverage for durable medical equipment shall include:
Additional coverage shall require annual hearing exams and one hearing aid per ear every three years. The expected effective date is January 1, 2027.
California: Health Insurance Coverage
As of October 13, 2025, California shall prohibit health insurance policies from imposing a copayment, coinsurance, deductible or any other cost-sharing payment format for insulin prescription drugs whose cost exceeds $35 for a 30-day supply.
Further, health insurers shall cover at least one insulin for a given drug type on the prescription drug formulary in all forms and concentrations.
Lastly, health plans are prohibited from requiring a step therapy prerequisite to authorize coverage of at least one insulin drug type.
California: Health Insurance Coverage
On October 13, 2025, California expanded Essential Health Benefits for residents enrolled in individual and small group health plans. The expected effective date is January 1, 2027.
The expanded coverage shall include:
California: Paid Family Leave
On October 13, 2025, California expanded the paid family leave program to cover employees seeking leave to care for seriously ill individuals beyond traditional family members. The expanded coverage introduces a family “designated person” into California’s family temporary disability insurance program. The “designated person” may be anyone related by blood or whose relationship with the employee is reasonably equivalent to a family connection. Employees seeking first time coverage to care for a “designated person” must identify the individual and under penalty of perjury affirm how the blood relation or how the relationship is a family equivalent relationship. The expected effective date is July 1, 2028.
California: CalRx
On October 16, 2025, California declared that CalRx will cover the pen form of Insulin Glargine at a suggested retail price of no more than $55 for a five pack of pens.
California: Workers’ Compensation
On October 17, 2025, the Workers’ Compensation Insurance Rating Bureau of California (WCIRB) released Bulletin 2025-16. The Bulletin explains 12 legislative updates to workers’ compensation insurance.
Colorado: Health Insurance Subsidies
On September 29, 2025, the Colorado Division of Insurance published the Amended Regulation 4-2-78. This Amended Regulation advises residents with household incomes up to 400% of the Federal Poverty Level (FPL) of their eligibility for premium subsidies when purchasing individual health insurance plans through the state’s exchange. The expected effective date is November 30, 2025.
Delaware: Paid Family and Medical Leave
On October 2, 2025, the Delaware Department of Insurance released Bulletin 158 which details requirements for insurance companies offering private paid family and medical leave plans. These insurance carriers are required to provide benefits equivalent to those in the state-run program. No restrictions are to be added that exceed statutory requirements. Carriers whose policies include “conformity clauses” or provisions that automatically update coverage upon a legal change are exempt from refiling. Insurers submitting significant changes to coverage terms, benefit structures, or eligibility requirements that are not covered by such clauses must submit these modifications to the Department of Insurance for approval.
Private plan employers shall follow a quarterly approval date format (Jan 1, Apr 1, Jul 1, Oct 1) for applications to the Department of Labor. Claim documentation shall be needed if a claim goes to appeal, complaint, audit, or inquiry.
Small employers (25 or less employees) who voluntarily opt into the program will be subject to all provisions of the law, which includes employee appeal rights. Employers choosing the state-administered plan are required to obtain all mandatory coverage lines through the state program. These provisions are effective immediately.
District of Columbia: Health Insurance Rates
On September 30, 2025, the DC Department of Insurance, Securities and Banking (DISB) announced the 2026 health insurance rates approved for individual and small business plans. The final rates reflect average increases of 8.7% for individual plans and 9.5% for small group plans. Additional information on the 2026 health insurance approved rates can be found at www.disb.dc.gov/2026rates.
District of Columbia: Workers’ Compensation
Effective immediately, the District of Columbia initiated a permanent amending to the workers’ compensation rules which will allow, with certain restrictions, employees and their dependents to file D.C. claims for compensation despite being paid or awarded compensation for the same injury or death under the workers’ compensation law of another state.
Idaho: Health Insurance Rates
On October 3, 2025, the Idaho Department of Insurance published the 2026 final premium rates for individual and small group health insurance. Plans will increase by an average of 10% in the individual market and 11% in the small group market.
Idaho: Workers’ Compensation
On October 10, 2025, the Idaho Department of Insurance accepted a National Council on Compensation Insurance filing that reduces workers’ compensation rates by 2.5%. This rate reduction shall be effective January 1, 2026.
Louisiana: City of New Orleans
Effective immediately, the City of New Orleans requires heat illness prevention measures be taken for employees of all contractors, vendors, or suppliers who are a party to a contract, professional services agreement, cooperative endeavor agreement, or grant agreement with the city. The heat illness prevention breaks must include:
in a work location without air conditioning, when the heat index measures 80-89 degrees Fahrenheit
These measures include regular rest breaks in an area protected from direct sunlight.
Maine: Medicare
On October 17, 2025, the Maine Bureau of Insurance advised enrollees in the Medicare Advantage plans to prepare for significant changes in 2026. Several health insurers are reducing the number of Medicare Advantage plans they offer in Maine or exiting certain areas of the state.
Massachusetts: Paid Family and Medical Leave
On October 3, 2025, the Massachusetts Department of Family and Medical Leave (DFML) published updated contribution amounts that need to be remitted by eligible employees and employers as of January 1, 2026. The PFML 2026 Employer Contribution Rates maintains the 2025 rate. The 2026 maximum weekly PFML benefit amount is set at $1,230.39 per week.
Massachusetts: Paid Family and Medical Leave
On October 15, 2025, the Massachusetts Department of Family and Medical Leave (DFML) released a Memo explaining how the IRS Revenue Ruling 2025-4 affects the state’s Paid Family and Medical Leave (PFML) program. The federal ruling details changes for tax treatment and the reporting of medical leave benefits.
The new rules explain when employers who are required to pay medical leave contributions will be responsible for remitting the employer share of FICA (Social Security and Medicare) and FUTA (federal unemployment) taxes on certain medical leave benefit payments made to employees on or after January 1, 2026. These employers shall also be responsible for reporting the taxable portion of medical leave benefits on the employee’s W-2.
Michigan: COVID Vaccines
On October 16, 2025, the Michigan Department of Insurance and Financial Services released Bulletin 2025-23-INS instructing health insurers that they must continue covering Covid-19 vaccinations without charging out-of-pocket costs. Insurers operating in the state’s individual and small group health insurance markets will be subject to this requirement.
Minnesota: Health Insurance Rates
On October 1, 2025, the Minnesota Department of Commerce announced the 2026 health insurance rates for individual and small group plans. Under the 2026 rates, individuals purchasing health insurance through the individual market can expect an average rate increase of 21.5%, while those who purchase through the small group plan options can expect a 14.2% increase.
Minnesota: Paid Family and Medical Leave
Effective November 1, 2025, Minnesota’s Paid Family and Medical Leave (PFML) shall prohibit employers from retaliating or discriminating against employees who request or use PFML benefits or exercising their PFML rights.
Minnesota: City of Minneapolis
Effective December 31, 2025, the Minneapolis, Minnesota, Sick and Safe Time Ordinance shall be amended to align with the state’s Earned Sick and Safe Time law. The city’s ordinance shall require employers with one or more employees to provide paid sick leave. Prior ordinance was limited to employers with fewer than six employees. The amendments also affect the following:
Minnesota: Health Insurance Rates
On October 1, 2025, the Minnesota Department of Commerce announced finalized 2026 health insurance rates for the individual and small group plans. The individual market will increase by 21.5% while the small group market will increase by 14.2%.
Minnesota: Workplace Notice
The state of Minnesota has made available a link to its paid leave workplace notice, Required posters and notices / Minnesota Paid Leave
Minnesota: Paid Leave
The State of Minnesota has made available a link to its Paid Leave postcard, Minnesota Paid Leave is coming. Is your business ready?
Nebraska: Apprenticeships
On October 14, 2025, Nebraska issued an Executive Order to launch the Good Life, Great Careers Initiative with the goal of creating and strengthening apprenticeship and pre-apprenticeship programs. The initiative is focused to support the manufacturing, healthcare, transportation, construction, the bioeconomy, and other high-demand industries.
As part of the Good Life, Great Careers Initiative, the Nebraska Department of Labor (NDOL) is creating the Office of Registered Apprenticeship. The Office is designed to serve as NDOL’s hub for all matters related to registered apprenticeship programs.
Nevada: Medicare
On September 30, 2025, the Nevada Division of Insurance released Bulletin 2025-02 in order to clarify NV S.B. 292. The regulations permit residents who are under the age of 65 and eligible for Medicare to purchase supplemental insurance policies starting in 2026. The initial open enrollment period began October 1, 2025.
New Hampshire: Medicare
On October 1, 2025, The New Hampshire Insurance Department (NHID) informed residents regarding changes to Medicare Advantage resulting from the carrier reducing plan offerings and its withdrawal from the market. The NHID expects these changes to have significantly varying effects by county. WellSense and Humana will remain the only carriers in Coos County. Aetna will exit the markets in Belknap, Carroll, Cheshire, Grafton, Merrimack, Strafford, and Sullivan counties. Humana will discontinue one of its plans in Carroll County. Humana will introduce new plan options for Belknap, Carroll, Hillsborough, Merrimack, Rockingham, and Strafford counties. Anthem and Martin’s Point will no longer offer any individual plans statewide.
New Hampshire: Medicare
On October 2, 2025, the New Hampshire Insurance Department (NHID) released Bulletin INS 25-074-AB which clarifies when insurance producers may charge consumers reasonable fees for services that are incidental to the sale, solicitation, or negotiation of Medicare Advantage and Medicare Supplement coverage. The bulletin details that producers are permitted to enter into agreements with consumers with a reasonable service charge or fee for services that are incidental or related to, but not part of, those sales activities.
The bulletin instructs producers who wish to enter into such agreements of their requirement to disclose the fee arrangement and obtain the consumer’s approval to the fee arrangement prior to any services being performed or billed. Producers should maintain detailed accounting of the services rendered and their related billing.
New Mexico: Health Insurance Exchange
On October 3, 2025, New Mexico authorized residents earning up to 400% of the federal poverty level to purchase plans on the state exchange even if they don’t qualify for federal premium tax credits. The current eligibility for the exchange is based on qualifying for federal subsidies.
New Mexico: Pharmacy Benefit Manager (PBM)
On October 14, 2025, the New Mexico Office of the Superintendent of Insurance (OSI) announced Bulletin 2025-011 to repeal Bulletin 2023-001 and Bulletin 2023-035 addressing procedures for PBMs. The new procedures authorize PBMs to receive perpetual licenses rather than annual renewals. The change in licensing format will not impact the PBMs obligation to pay annual fees totaling $700 ($500 for license continuation and $200 for their annual report). The fees shall both be due by March 1.
New York: COVID Vaccines
On October 3, 2025, New York extended Executive Order 52 which permits pharmacists to administer COVID vaccines.
New York: Retirement Savings
On October 8, 2025, New York reported the launch of the New York State Secure Choice Savings Program. This is a state-sponsored retirement savings program for private sector employees who have no access to a workplace retirement plan. The program is available to New York employers with ten or more employees who currently do not offer a qualified retirement plan. New York Secure Choice will advise employers on the facilitation of the program and provide registration details. Eligible employers can enroll at: www.NewYorkSecureChoice.com
New York: Health Insurance Coverage
On October 16, 2025, Gov. New York enacted the Eli Parker Levitt Law. This new law requires health insurance plans to cover medically necessary transvaginal ultrasounds during pregnancy. The expected effective date is January 1, 2027.
North Carolina: Prescriptions
On September 29, 2025, the North Carolina Department of Insurance released Bulletin 25-B-12 which reminds health insurers that residents are permitted to receive emergency prescription refills due to Tropical Depression 9-Imelda.
North Dakota: Health Insurance Rates
On October 15, 2025, the North Dakota Insurance Department announced the approved 2026 rates for Affordable Care Act (ACA) plans. The rates reflect a 12.7% increase for individual plans and a 6.6% increase for small group plans. The rates can be found at: North Dakotans Could See Significant Health Insurance Premium Increases in 2026 if Federal Subsidies End | North Dakota Insurance Department
Oklahoma: Legislative Changes
On September 30, 2025, the Oklahoma Insurance Department released Bulletin 2025–04 detailing the following health insurance legislative changes:
Oklahoma: Workers’ Compensation
Effective November 1, 2025, the Oklahoma’s Administrative Workers’ Compensation Act excludes the following individuals from the definition of employee:
Oklahoma: Health Insurance Coverage
On October 17, 2025, the Oklahoma Insurance Department released Bulletin 2025-06 to ensure uniformity in the application of the state’s mandated biomarker testing coverage. The bulletin informs insurers that they must accept any of five categories of medical evidence to establish a test’s utility, including Food and Drug Administration approvals, Medicare coverage determinations, or nationally recognized clinical guidelines. In cases where a test meets more than one standard and is subject to varying restrictions, insurers are required to apply the least restrictive criteria.
Insurers are instructed to ensure that the coverage minimizes disruption in patient care. This shall include reducing the need for multiple biopsies and that medical policies are to explicitly acknowledge Oklahoma’s law and their respective requirements.
Oregon: Workers’ Compensation
On September 30, 2025, the Oregon Workers’ Compensation Division issued Revised Bulletin 247 describing the format for certified Managed Care Organizations (MCOs) to submit quarterly reports to the Department of Consumer and Business Services under OAR 436-015-0040(4). The bulletin updates the following:
Oregon: Prescription Pricing
On September 30, 2025, the Oregon Division of Financial Regulation issued its 2025 Pharmacy Benefit Manager Price Transparency Report: Oregon Drug Price Transparency Report: Pharmacy Benefit Manager Data – 2025
Oregon: Health Insurance Rates
On October 8, 2025, the Oregon Division of Financial Regulation released the 2026 health rates for the individual and small group plans.
Oregon: Workers’ Compensation
On October 13, 2025, the Oregon Workers’ Compensation Division released Revised Bulletin 248 detailing the current Managed Care Organization’s GSAs. The division shall provide an updated Exhibit A (Oregon ZIP Codes). This bulletin replaced Bulletin 248 which was issued on April 27, 2017.
Pennsylvania: Vaccines
On October 1, 2025, Pennsylvania released Executive Order 2025-02 to authorize the Pennsylvania Department of Health to establish a state-based safety net that will protect children’s access to vaccines. The order also requires all state agencies to align policies with trusted medical experts.
Pennsylvania: Health Insurance Rates
On October 14, 2025, the Pennsylvania Insurance Department (PID) announced the 2026 ACA health insurance rates. The small group rate increase reduced its increase from 13.1% to 12.7%, while the individual market rates increased by an average of 21.5%.
Pennsylvania: Vaccines
On October 18, 2025, the Pennsylvania Insurance Department (PID) issued Notice 2025-09. Per the Notice, insurers who have accident and health authority and issue policies in the Commonwealth shall continue to cover vaccines. The vaccines shall be offered without cost sharing or other administrative barriers.
South Carolina: Health Insurance Coverage
On October 1, 2025, the South Carolina Department of Insurance released Bulletin 2025-09 which instructed health insurers to increase the maximum annual benefit for autism behavioral therapy coverage to $73,400.
Texas: Health Insurance Eligibility
On September 29, 2025, the Texas Department of Insurance released Commissioners Bulletin B 14–25 which amends Insurance Code Section 544.002 in order to prohibit an insurer from discriminating against an individual who is widowed by:
Washington: Ambulance Rates
On October 10, 2025, the Washington State Office of the Insurance Commissioner (OIC) issued a reminder regarding ground ambulances and balance billing.
Wyoming: Workers’ Compensation
On October 15, 2025, the Wyoming Department of Workforce Services proposed a reduction in workers’ compensation base rates by 15% for 2026. Some employers could see total reductions of up to 27.75% depending on their industry classification. The 2026 proposed rates are available here: NOTICE OF HEARING: Proposed 2026 Workers’ Compensation Employer Industry Base Rates – Wyoming Department of Workforce Services
DISCLAIMER
The information provided by The Fedeli Group’s Compliance Alert is not intended to be, nor should it be, interpreted as conferring legal advice to the reader of the Compliance Alert. The Fedeli Group Compliance Alerts are designed specifically and solely for informational purposes. Should the reader have any legal questions or concerns after reading this Compliance Alert, it is recommended that the reader seek counsel for a formal opinion.
Our mission is to help clients protect assets and enhance employee outcomes through the delivery of exceptional risk management and employee benefit consulting services and products.
Receive our most recent blog articles, insights & news delivered straight to your inbox.
