December 30, 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.
Alaska: Pharmacy Benefit Managers (PBM)
Effective December 2, 2025, the Alaska Division of Insurance issued changes to Alaska insurance regulations that include requiring all PBMs to obtain a state license that includes an application fee of $20,000.
Additionally, licensing terminology has been modified to better match a framework used across multiple states. As an example, the insurance line previously referred to as “Health” will now be called “Accident, Health and Sickness” which falls in line with the Producer Licensing Model Act.
Alaska: Workers’ Compensation
On November 26, 2025, the Alaska Division of Insurance announced that effective January 1, 2026, an overall 3.7% reduction in voluntary loss costs and a 4.8% decrease in assigned risk rates based on the National Council on Compensation Insurance’s filing.
California: Personnel Files
As of January 1, 2026, California employers are required to maintain education and training records in employee personnel files. These records shall be made available for review by current employees, former employees, or their representatives upon request.
California: Wage Garnishment
As of January 1, 2026, employers shall begin withholding funds for creditor garnishment orders at 30 days after receiving the withholding notice and order. If the employer is made aware that the employee filed a claim of exemption before the end of business on the 29th day after the employer received the order, the withholding period shall begin 45 days from the date that the employer received the notice and order.
Employers are required to document and provide the date the employer gave the withholding notice and order to the employee, the name and title of the person who delivered it and a description of the delivery method.
California: Workers’ Compensation
As of January 1, 2026, California requires all interested parties reveal any financial interest alleged to exist in a workers’ compensation claim. This disclosure must be issued to a third-party payer or other entity that the claim is presented for payment.
California: Pay Data Reporting
As of January 1, 2026, California employers regulated by the California pay data reporting law are required to maintain a separate set of demographic data for reporting purposes from employees’ personnel records. Should an employer fail to submit the report upon request by the California Civil Rights Department a court imposed a civil penalty may be applied to the employer.
California: Equal Pay Act
As of January 1, 2026, the California Equal Pay Act (CEPA) statute of limitations shall be extended to three years after the last date of an alleged violation. Additional CEPA amendments include:
Colorado: Health Care Price Transparency
Effective January 30, 2026, the Colorado Division of Insurance (CDOI) is requiring insurance carriers to publish negotiated rates with medical providers and share prescription drug cost data with state officials every January and July. Insurers must submit three data files containing negotiated rates with in-network providers, out-of-network charges, and data directing consumers to plan-specific pricing information. The data shall be published in JSON format and published on the carriers’ websites.
Colorado: Prescription Coverage
Effective January 30, 2026, the Colorado Division of Insurance shall require insurance carriers to provide annual reports as to how they cover medications used to treat substance use disorders such as opioid addiction. Reporting shall be due every April and are to include network providers authorized to prescribe these treatments, the number of patients receiving the care and any restrictions to access the medications. Additionally, insurers shall verify that they are including at least one F.D.A. approved medication for substance use disorders on the lowest-cost tier of their formularies. Insurers shall also disclose under what circumstances prior authorization or other restrictions are required which may result in the delay of treatment, specifically for pregnant patients and minors.
Colorado: Pharmacy Benefit Managers (PBM)
Effective January 30, 2026, the Colorado Division of Insurance (CDOI) is requiring all PBMs to register with the CDOI by July 1st of each year and pay a $2,500 fee. Additionally, PBMs shall disclose their corporate structure, leadership and the insurance carriers that they contract with in Colorado. The PBMs shall also detail their compliance procedures for state pharmacy laws and disclose any history of regulatory sanctions in other states.
Colorado: Limited Benefit Plans
On December 3, 2025, the Colorado Division of Insurance (CDOI) issued guidance to explain the differences between Affordable Care Act (ACA) compliant plans and limited benefit plans. The CDOI guidance details that limited benefit plans do not meet the requirements of the ACA. Limited benefit plans may include short-term plans, trade association plans and discount plans. These plans and products are not sold through Connect for Health Colorado and are often sold through unsolicited calls and text messages from brokers who are not affiliated with Connect for Health Colorado.
Colorado: Workers’ Compensation
On December 4, 2025, the Colorado Division of Workers Compensation reminded stakeholders to use up-to-date forms that utilize the divisions updated address of 707 17th St. 2300 Denver, CO 80202.As of January 1, 2026, the Division will no longer accept forms with their old address. PDF versions of all current forms can be obtained from the DOWC Forms webpage.
Colorado Insurance Licensing
Effective December 15, 2025, Colorado’s Division of Insurance (DOI) shall no longer accept new registrations for online insurance licensing examinations.
In addition:
Colorado Paid Family and Medical Leave (PFML)
The 2026 PFML premium contribution rate shall be reduced to 0.88% of wages per employee. Each subsequent year’s premium shall be set by September 1 of the proceeding calendar year.
Colorado: Prior Authorization
The Colorado Division of Insurance announced that health insurers shall post data on prior authorization approvals, denials and exemptions by May 1, 2026. This was previously scheduled to be due by January 1, 2026.
Delaware: Paid Family and Medical Leave (PFML)
Effective December 11, 2025, the following amendments to the Healthy Delaware Families Act include:
As of January 1, 2026, employees may access PFML benefits.
Illinois: Nursing Mothers in the Workplace Act Accommodations
Effective January 1, 2026, the Illinois Nursing Mothers in the Workplace Act shall be amended to require covered employers to compensate employees at their regular rate of pay while taking lactation/breastfeeding breaks. It shall be impermissible for employers to require employees to use paid leave during lactation/breastfeeding breaks or to require that employees accept a reduction of their compensation during the break time in any other manner.
Illinois: Employer Filings
Effective January 1, 2026, Employer who did not timely file the required new hire reports or monthly unemployment insurance wage reports, may be subject to an Illinois Department of Employment Security injunction that prohibits the employer from doing business in Illinois while the reports are unfiled. The IDES shall provide the delinquent employer with a 30 days’ written notice before requesting court enforcement of the injunction.
Illinois: Employee Protections
Effective January 1, 2026, the Illinois Workplace Transparency Act (IWTA) shall be amended to make impermissible agreements that prohibit, prevent or otherwise restrict employees, prospective employees or former employees from engaging in concerted activity to address work-related issues for the purpose of collective bargaining or other mutual aid or protection.
The amendments shall also:
Illinois: Employee Leave
Effective January 1, 2026, the Illinois Employee Blood and Organ Donation Leave Act shall be amended to permit part-time employees to use up to 10 days of paid leave to donate an organ and provide guidance on compensating part-time employees for the leave days used.
Louisiana: Health Insurance Coverage
On November 25, 2025, the Louisiana Department of Insurance (LDI) issued a requirement that health insurers provide equal reimbursement for medical psychologists who prescribe medications and manage mental health treatment. The prescribing psychologists shall utilize CPT Code 90863 when providing medication management alongside psychotherapy. Insurers shall pay medical psychologists at rates consistent with what they pay other licensed prescribers performing the same services.
Maine: Direct Care
On December 1, 2025, the Maine Bureau of Insurance broaden the scope of direct primary care arrangement where patients pay physicians directly, rather than billing through insurance. Under the broadened approach, there is now coverage for all licensed physicians, advanced practitioners and specialists. Health carriers cannot deny coverage for referred services. It shall be impermissible to implement cost-sharing requirements solely because the referring physician practices outside their network or operates on a direct-care basis.
Maine: Insurance Marketing
On November 24, 2025, Maine Bureau of Insurance (Bureau) began alerting consumers searching for health insurance online may be contacted by salespersons offering to enroll them in coverage through LifeX Research Corporation. These consumers are being told they will be covered by LifeX’s health plan by becoming LifeX employees.
The Bureau’s alert includes that “any health plan being offered by LifeX is not a major medical health insurance plan regulated by the Bureau. Some Maine consumers have been told the LifeX health plan will be issued by a well-known health insurer. This is not true. None of the licensed health insurers offering major medical coverage in the State of Maine provide coverage to Maine consumers through LifeX.”
New Hampshire: Employee Leave
Effective January 1, 2026, New Hampshire employers with 20 or more employees shall be required to provide up to 25 hours of unpaid leave for:
New Hampshire: Family Military Leave
Effective January 1, 2026, employers with 50 or more employees at the same location in New Hampshire shall be prohibited from terminating, refusing to hire or taking any adverse employment action against an employee based on the involuntary mobilization of the employee’s spouse in response to a declaration of war, national emergency or contingency operation. An employee’s leave of absence due to the spouse’s involuntary mobilization shall be unpaid, and the employee shall generally be entitled to be reinstated to the same or a comparable position.
New Jersey: Health Insurance Coverage
The New Jersey Department of Banking and Insurance introduced final rules implementing cost caps for insulin, asthma inhalers and epinephrine auto-injectors. Specifically, health insurers shall limit patient insulin costs to $35 per month for any 30-day supply. Asthma inhalers shall not exceed $50 for a month’s supply, and epinephrine auto-injectors, such as EpiPens, are capped at $25.
New Jersey: Childhood Immunizations
On December 5, 2025, the New Jersey Department of Banking and Insurance stated that regardless of federal policies for childhood immunization schedules, insurance carriers shall provide coverage for childhood immunizations as per New Jersey Department of Health recommendations. The hepatitis B vaccination series shall be administrated based on State law and with no cost sharing or additional restrictions.
New York: Pharmacies
As of December 12, 2025, pharmacies that are permanently closing are required to notify customers who filled prescriptions within the past year about the planned closure. The pharmacies shall be required to provide notice either by email, text or mail. Additionally, the pharmacies will be required post signs about the closure in visible locations.
New York: Health Insurance Plans
As of December 12, 2025, high-deductible health plans with health savings accounts are permitted to comply with federal tax code requirements without losing their tax advantaged status. Any cost-sharing requirements shall apply to high-deductible plans only after the plan participants satisfied the minimum deductible required by federal law. Preventive care services shall run consistent with federal rules by remaining exempt from the deductible requirement.
This rule modification will apply to individual policies, group & blanket insurance, and health maintenance organizations (HMOs).
New York: Health Insurance Coverage
Effective January 1, 2026, health insurers are required to cover follow-up screening or diagnostic services for lung cancer without patient cost sharing.
New York: Employee Accommodations
On December 5, 2025, reasonable accommodations under New York state anti-discrimination law were expanded. The modification prohibits employee retaliation against requests for reasonable accommodations that include modifications to work schedules, physical workspaces or job duties in order to accommodate disabilities, religious practices or other protected characteristics. These and other similar requests shall be deemed a protected activity alongside opposing discrimination and participating in discrimination proceedings.
North Carolina: Gender Definition
Effective January 1, 2026, North Carolina shall recognize two sexes, male and female, and an individual’s preference of gender identity will not be treated as legally or biologically equivalent to sex under state law. North Carolina has also introduced new definitions of biological sex, gender identity, female, male, and other related terms.
Oklahoma: Workers’ Compensation
On December 8, 2025, the Oklahoma Workers’ Compensation Commission published the 2024 WCC Handbook. The handbook details respective rules, forms, benefit charts, Session Laws, Title 85 and Title 85A provisions.
Oregon: Workers’ Compensation
On December 11, 2025, the Oregon Workers’ Compensation Division notified insurers and self-insured employers of the 2026 claims processing administrative cost factor. The Workers’ Compensation Division applies this cost factor to applicable reimbursements for supplemental disability benefits and certain claim costs. Additionally, the cost factor is utilized in the calculation of self-insured employer security deposits.
Pennsylvania: Health Insurance Coverage
On November 24, 2025, the state modified the mammography coverage law to cover annual mammograms for women 40 and older. Additional coverage was added for supplemental screening using magnetic resonance imaging or ultrasound for women deemed at average risk or higher for breast cancer.
Insurers are required to cover the screenings without cost-sharing such as copayments or deductibles. The modifications have no impact to coverage under workers’ compensation, dental, and vision plans and Medicare supplements. The expected effective date is listed as January 23, 2026.
Pennsylvania: Hair Discrimination
On November 25, 2025, an amendment was approved for the Pennsylvania Human Relations Act (PHRA) aka the Creating a Respectful and Open World for Natural Hair (CROWN) Act. Under the Act, employers are prohibited from discriminating against employees or applicants based on hairstyles such as locs, braids, twists, coils, bantu knots, afros, and extensions. The expected effective date is January 24, 2026.
South Carolina: Employer Withholding
Effective January 1, 2026, employers and payroll service providers are required to use the South Carolina Department of Revenue 2026 Withholding Tables.
South Carolina: Medicare
On November 24, 2025, the South Carolina Department of Insurance (SC DOI) published guidance advising insurers and producers that the SC DOI shall investigate any insurer that:
The SC DOI stated that insurers cannot detail commission percentages in their rate filings and then reduce these commissions to zero in order to discourage enrollment. If a plan remains approved for sale in South Carolina and no formal withdrawal has occurred, insurers are required to make enrollment reasonably available through all customary formats such as online, by mail, and through licensed agents.
Texas: Workers’ Compensation
The Texas Division of Workers’ Compensation announced an expected effective date of December 24, 2025, for the amending of regulations governing who qualifies for supplemental income benefits. Specifically, the amendment shall change the use of the word “for” with “to obtain” in order to mirror the language of the Texas Labor Code.
Washington: Unclaimed Wages
Effective January 1, 2026, employers are required to employees of unclaimed wages of $5 or more while the aggregate report value is lowered to under $5.
Washington: Workers’ Compensation
The Washington State Department of Labor & Industries announced the Workers’ Compensation premium shall increase 4.9% for calendar year 2026. The increase is based on an average for all industries. However, the rate for specific industries could be higher or lower, depending on the recent history of injuries that led to claims for the specific industry.
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.
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