[update] State Legislative and Reporting Updates – July 1, 2025

In response to the continuing state regulatory activity involving health plan 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 Workers’ Compensation

The California Workers’ Compensation Insurance Rating Bureau (WCIRB) released their September 1, 2025, versions of the following publications:

• California Workers’ Compensation Uniform Statistical Reporting Plan—1995(USRP) 
• California Workers’ Compensation Experience Rating Plan—1995 (ERP) 
• Miscellaneous Regulations for the Recording and Reporting of Data— 1995 (Miscellaneous Regulations) 
• California Basic Underwriting Manual These resources are available in the Filings and Plans section of the WCIRB website or directly through the links above.

California Health Insurance Coverage

Effective July 1, 2025, employer sponsored health plans issued or renewed on or after July 1, 2025, will be required to provide health plan coverage for the diagnosis and treatment of infertility, which to include up to three completed oocyte retrievals and unlimited embryo transfers.

Colorado Paid Family and Medical Leave

Effective January 1, 2026, the Paid Family Medical Leave (PFML) premium contribution rate shall be reduced to 0.88% of wages per employee. Beginning in the calendar year of 2027, future PFML premium contribution rates will be determined by September 1 of the current calendar year for an effective date of the start of the following year. This data shall be published before January 1 of the following calendar year.

Illinois Health Insurance Coverage

Effective June 9, 2025, Illinois is requiring health insurers to provide coverage to “all medically necessary” FDA approved treatments and medications that are prescribed to reduce the progression of Alzheimer’s as well as other dementia related conditions which are under the treatment plan of a licensed physician. Patients shall not be subjected to cost control treatment practices designed to require less expensive treatment options prior to prescribed medications consideration. Under this new regulation, coverage of medically necessary diagnostic testing that assists treating physicians in designing appropriate treatment plans for these conditions is authorized.

Indiana Reporting Requirements

On June 10, 2025, the Indiana Department of Insurance issued Bulletin # 278 detailing the new ownership disclosure requirements for insurers, Pharmacy Benefit Managers (PBMs) and Third-Party Administrators (TPAs). Under the regulation, covered entities must file annual reports listing any individual or organization holding a minimum of 5% ownership interest. The effective date is currently slated for July 1, 2025.

The report shall include:

• Business addresses;
• Applicable websites;
• Identification numbers; and
• Ownership percentages

Iowa Health Insurance Coverage

Effective on January 1, 2026, Iowa is requiring health plans to remove annual and lifetime benefit limits in the treatment of autism spectrum disorder. In addition, health plans are required to remove restrictions as to the number of outpatient visits patients may have with their practitioners. Plans shall continue to provide a minimum of 30 inpatient covered visits and 52 outpatient covered visits annually with no limit restrictions for autism-specific service visits.

Iowa Pharmacy Benefit Manager (PBM)

On June 11, 2025, Iowa approved a regulation to prohibit PBMs from participating in the following practices:

• Steering patients away from their preferred pharmacies through financial penalties or incentives;
• Denying network participation to qualified pharmacies who meet plan requirements and agreed to standard reimbursement terms;
• Imposing certification or credentialing requirements that exceed state licensing standards;
• Inappropriately altering drug designations as “specialty” medications, which is likely to trigger a restriction as to where patients can obtain prescriptions;
• Requiring that payment arrangements between insurers and PBMs mirror the payment arrangements, including the applicable professional fees, between PBMs and dispensing pharmacies;
• Requiring PBM payment arrangements with retail pharmacies to include a $10.98 professional dispensing fee;
• PBMs engaging in reimbursement arrangements that provide more favorable reimbursements to PBM affiliated pharmacies and less favorable reimbursements to independent competitors for the same medications; and
• Requiring that PBMs provide quarterly reporting to state regulators detailing all drugs reimbursed at rates that are at least 10% above or below the national average acquisition costs. The reports must include dispensing details, reimbursement amounts and whether the pharmacy has a PBM affiliation.

Louisiana Medicare – Employer Healthcare

The Louisiana Senior Health Information Program published its guide for employers and Medicare eligible employees.

Maine Prescriptions

Retail pharmacies are permitted to establish remote dispensing sites for underserved rural communities. The Maine Board of Pharmacy shall, by June 30, 2026, develop regulations governing how these remote locations operate. The sites shall be staffed with onsite pharmacy technicians but supervision by licensed pharmacists may be conducted through telehealth technology.

Maine Paid Family and Medical Leave

The Maine Department of Labor announced that it has contracted with Aflac to administer the newly enacted Maine Paid Family and Medical Leave program. Effective May 1, 2026, eligible workers in the private and public sector will have up to 12 weeks of paid time off for the following:

• to care for a family member with a serious health condition;
• to care for a child / dependent resulting from a new birth, newly fostered care arrangement, or adoption;
• to care for their own medical needs:
• to deal with the transition of a family member’s impending military deployment; or
• to stay safe after abuse or violence.

The Maine Department of Labor announced that the state Average Weekly Wage (SAWW) applicable to the Paid Family and Medical Leave program shall be increased to $1,198.84 for the period of 7/1/2025 to 6/30/2026.

The Paid Family and Medical Leave law is amended to:

• Clarify that intermittent leave cannot be taken in increments of less than one workday;
• Remove the term reduced leave schedule but shall continue to permit a lesser increment of at least one hour if agreed to by the employee and employer;
• Remove the provision permitting that the taking of intermittent leave or a reduced leave schedule will not result in a reduction of the total amount of leave that an employee is permitted.

Minnesota Unemployment Insurance

Under the expected effective date of January 1, 2026, penalties have been increased for employer unemployment insurance fraud. Specifically, the following measures have been authorized:

• Penalties shall be doubled against employers who make false statements or fail to cooperate with unemployment investigations;
• Fines shall be increased from 50% to 100% of the resulting overpaid benefits or unpaid contributions; and
• The application of the additional $500 penalty for employers who fail to comply with subpoenas shall remain.

Minnesota Family and Medical Leave

The Minnesota’s Family and Medical Leave Insurance Program, under an expected effective date of January 1, 2026, has reduced the maximum annual premium rate charged to employers from 1.2% to 1.1% of taxable wages. The program shall also require annual actuarial analysis to determine the program’s financial health and any suggested adjustments. Adjustments to premiums shall be constructed to ensure that the fund balance remains at a minimum of 25% of total program expenses.

Minnesota Medicare

Individuals aged 65 to 70 are permitted on an annual basis to purchase Medicare supplemental coverage without a medical underwriting requirement. Late enrollment will generate premium surcharges of 15% to 35%.

Minnesota Individual Health Insurance

Health insurers discontinuing individual health plans shall be required to:

• Provide written notice to regulators by May 1 of the preceding year;
• Give a 90 day notice to affected enrollees;
• Provide guaranteed-issue alternatives from their current portfolio; and
• Act uniformly without regard to an enrollee’s health status.

Minnesota Medical Marijuana

Minnesota grants immediate employment protections to tribal medical cannabis patients which includes antidiscrimination and anti-retaliation protections. Employers are required to provide the employee with written notice should the employer decide to take a typically prohibited adverse employment action against the employee.

Montana Workers’ Compensation

Effective October 1, 2025, Montana’s Workers’ Compensation Act is amended to create a presumption of responsibility for the worker’s compensation premiums and loss experience to employers utilizing a worker provided through another person or firm, except temporary service contractors. The presumption can be overturned when:

• The company providing the worker maintains complete control over all aspects of the worker’s duties; or
• The company carries workers’ compensation insurance for the worker. This option shall no longer be applicable as of October 1, 2025.

Nebraska Professional Employer Organization (PEO) – Health Plans

PEOs are required to:

• Offer self-funded health plans when utilizing licensed third-party administrators to hold plan assets in trust accounts in a manner that is consistent with federal ERISA standards;
• Maintain adequate reserves based on actuarial standards;
• Provide quarterly reporting to the state Department of Labor which includes financial statements and verification of stop-loss insurance coverage; and
• Provide employee notice when health plans are self-funded rather than fully insured.

Nebraska Prior Authorization

Effective January 1, 2026, health insurers are prohibited from requiring prior authorization for emergency services, certain preventive care, and services rated A or B by the U.S. Preventive Services Task Force. Health services received will be automatically deemed authorized should the insurers miss their decision deadlines. Nebraska shall require claim appeals to be reviewed by physicians with comparable specialties to the treating physician or have achieved equivalent experience treating the condition in the appeal. The legislation also includes: 

• Requirements that adverse authorization determinations issued prior to the treatment shall only be considered when made by physicians who have current licensing, appropriate specialty training, and specific qualifications.
• Permits Nebraska to require standardized prior authorization forms by calendar year 2026.
• Requires medical insurance coverage for biomarker testing for the treatment of cancer, autoimmune diseases, neurological conditions that Alzheimer’s and Parkinson’s and other specified conditions starting in 2028.
• Prohibits the sole reliance on artificial intelligence (AI) algorithms to deny medical services and implements a requirement for insurers to report their use of AI in conducting utilization review processes.

Nevada Hospital Price Transparency

As of the January 1, 2026, current expected effective date, Nevada hospitals shall be required to collect for annual publishing: 

• Comprehensive pricing lists for all items and services, including charge master rates, negotiated rates with insurance companies, and cash prices.
• Lists of consumer-friendly “shoppable services” that cover at minimum 300 schedulable procedures or fewer if the hospital can appropriately verify that this number exceeds its normal procedure capacity.
• A detailed pricing breakdown of the highest and lowest negotiated rates with third parties, or use of price-estimator tools may serve as an acceptable alternative.

Nevada Health Insurance Coverage

As of the January 1, 2026, current expected effective date, health insurance plans shall be required to authorize women access to gynecological and obstetrical services without the need of prior authorization or referral from the primary care physicians. Additionally, women cannot be prohibited from designating obstetricians or gynecologists as a primary care provider.

Nevada Medicare

Individuals under 65 years of age may now purchase a Medicare Supplement Insurance Policy if they qualify for Medicare due to a disability or end-stage renal disease. Nevada shall recognize special enrollment periods, which include a six-month window based on an individual’s initial enrollment in Medicare Part B. Insurers are prohibited from denying coverage or relying on pre-existing conditions to exclude benefits. A transitional enrollment period of October 1, 2025, to April 1, 2026, to assist those individuals already enrolled in Medicare Part B due to disability or end-stage renal disease as of October 2025.

Nevada Health Insurance Coverage

As of the January 1, 2026, current expected effective date, group health insurance plans, health maintenance organizations, fraternal benefit societies and Medicaid shall cover claims for noninvasive prenatal screening “at any time during pregnancy” and the insurance providers are prohibited from requiring prior authorization.

As of the January 1, 2027, current expected effective date, health insurance plans shall cover claims for fertility preservation procedures where:

• the patient is diagnosed with breast or ovarian cancer; and
• the treatment may cause infertility.

Religious organizations are granted the opportunity to opt out of providing this required coverage based on religious grounds objections. Should an opt out objection occur, insurers must give policyholders written notice to policyholders detailing their refusal to cover these services.

Nevada Health Insurance Coverage

As of the January 1, 2026, current expected effective date, health insurers shall provide coverage for habilitative and rehabilitative speech-language pathology treatment services with specific emphasis on claims for individual under the age of 26 undergoing treatment for stuttering. The insurers are prohibited from:

• applying annual limits on speech therapy visits;  
• applying the underlying cause of stuttering as a basis to restrict coverage; or
• applying prior authorization or step therapy requirements in the administration of these benefits.

Nevada Workers’ Compensation

The workers’ compensation program was amended by Governor Joe Lombardo on June 10, 2025. Employers should review the changes and determine whether new notice requirements shall be applied.

Nevada Drug Formulary Requirements

Effective in 2027, outpatient prescription drug coverage claim decisions shall be standardized through the reliance of the Official Disability Guidelines (ODG) Drug Formulary as published by MCG Health.

Nevada Injury Account Changes

Self-insured employer associations are prohibited from using the Subsequent Injury Account requirement that limits coverage qualification to subsequent injuries that occurred before October 1, 2025.

Nevada Physician Network Changes

Insurers are required to maintain sufficient lists of physicians and chiropractors, with specific minimums for different specialties. The insurers must also abide by new restrictions in the process to remove doctors from their approved provider lists.

Nevada Mental Health Coverage

Stress-related injury coverage has expanded to include psychological evidence alongside medical evidence and psychiatric evidence. Insurers are required to maintain lists of mental health providers. It is imperative that employers and plan sponsors review these coverage expansions as a number of these expanded coverages have become effective immediately. Other amendments such as the drug formulary requirements shall become effective on July 2027 and changes to the premium calculation shall take effect in October 2026.

Nevada Workers’ Compensation

Insurers are required to provide full reimburse treatment costs within 30 days for workers obtained care outside of the approved network. Insurers who miss the deadline may be liable for penalties which may be levied at up to double the unpaid amount of the treatment costs.

New Jersey Unemployment Insurance

Following a determination that state unemployment insurance (UI) contributions have surpassed projections, the New Jersey Department of Labor and Workforce Development announced a reduction in the UI tax rate paid by businesses. Businesses will be authorized to reduce their contribution rate to the “Column C” range of 0.5% to 5.8% from the current “Column D” rate which ranges from 0.6% to 6.4%.

New Mexico Payroll Tax

Effective July 1, 2025, the New Mexico employer payroll tax depositing and filing requirements will be modified for:

• Withheld taxes to be deposited monthly if the average taxes due exceed $500 per month. This modification is $200 per month increase.
• Employers shall file their withheld tax reports electronically. The prior reporting requirement was limited to those employers who file Form 41444 monthly and have an average liability of $1,000 or more.
• All employers shall file their W-2 Forms electronically. Previously, this requirement was limited to those employers who filed 25 or more W-2 forms.

New York New York City Earned Sick and Safe Time Act

Effective July 2, 2025, the New York City’s Earned Sick and Safe Time Act rule modifications shall require covered employers to recognize prenatal personal leave claims. This expansion of coverage is for employee pregnancy health care services.

Ohio Cost-Sharing Claim Measure Uniformity

The Ohio Department of Insurance (ODI) issued guidance surrounding Ohio House Bill 315 as stated under Ohio Revised Code 3902.63.  Specifically, ODI advised that cost-sharing measures such as copays, deductibles and coinsurance that are applied to the claim processing of services submitted by occupational therapists, physical therapists, and chiropractors cannot exceed the applicable cost-sharing measures applied to medically necessary primary care physician (PCP) office visit claims. Medical insurance providers will be updating their claims processing procedures to reflect these clarified limitations.

Oklahoma Workers’ Compensation

The Oklahoma Workers’ Compensation Commission announced that the Multiple Injury Trust Fund (MITF) assessment on workers’ compensation coverage providers shall be reduced from 7% to 6.29%.

Oregon Professional Employer Organization (PEO) – Regulatory Updates

Under the expected effective date of July 1, 2025, Oregon’s PEO regulations shall include the following changes: 

• The term “Professional Employer Organization” shall replace the eliminated term of “Worker Leasing Company”. 
• Two categories of workers will be recognized in the regulations. 1. “Covered Employees” are workers that the PEO assumes employer responsibilities, and 2. “Direct Hire Employees” references those who remain under the client company’s direct employment.
• Requirements for workers’ compensation coverage addressing employees in a PEO arrangement shall require that when the PEO offers coverage, the PEO shall notify insurers and maintain continuous protection until the PEO client acquires alternative coverage, or the PEO formally terminates its responsibility through a 30-day notice.
• Through the introduction of the “multiple coordinated policy basis” system, PEOs are permitted to utilize separate workers’ compensation policies for each client while coordinating premium obligations and communications.

Additionally, there are industry-specific changes that include the following:

• “Exempt” licensed construction contractors must now comply with the new PEO relationship requirements and no longer coordinate with the expired worker leasing arrangements.
• Retail, hospitality, and food service employers shall adjust their employment practices and scheduling to comply with the new definitions.

Oregon Paid Leave

The Oregon Employment Department announced increases in the minimum and maximum weekly benefit amounts (WBAs) for Paid Leave Oregon and Unemployment Insurance (UI) benefits. Effective July 6, 2025, the Paid Leave Oregon minimum WBA shall increase from $65.36 to $68.19 while the maximum WBA shall increase from $1,568.60 to $1,636.56. UI claims filed on or after June 29, 2025, will see the minimum WBA shall increase from $196 to $204 and the maximum WBA shall increase from $836 to $872. These are the result of the increase in Oregon’s State Average Weekly Wage from $1,307.17 to $1,363.80.

Oregon Professional Employer Organization (PEO) – Unemployment Benefits

For the purposes of unemployment insurance, PEOs are permitted to manage their contract workers as if they were PEO employees or as employees of the client company. The costs for unemployment benefits shall be applied to the entity accepts the contract workers as its employees. PEOs shall notify the State Employment Department as to the agreed upon election coordinated between the PEO and the client company. Should this election seek to be amended, the entities can do so with written notice and the understanding that the amended election shall remain for two years. PEOs that elect to report the contract workers as employees of the client employer shall be required to provide the necessary documentation within 60 days. Failure to comply with this deadline shall result in the contract workers being categorized as PEO employees. The effective date for these provisions will be the 91st day after the 2025 Oregon Legislative Assembly regular session adjourns.

Oregon Prescriptions

Drug manufacturers are prohibited from interfering with 340B entities’ ability to obtain, deliver or dispense discounted drugs through contracted pharmacies. Barring federal health officials introduction of new requirements, drug manufacturers are prohibited from insisting on additional claims or utilization data to establish eligibility to access these medications.

Oregon Pay Statements

Effective January 1, 2026, employers will be given the additional requirement to furnish new hires with detailed information regarding employee itemized pay statements and to ensure that this information is updated by the start of each calendar year. The required employer information shall include but not be limited to:

• All payroll codes used for pay rates and deductions with the respective detailed description or definition for each code.
• A comprehensive list of all employee eligible pay rates.
• All benefit deductions, contributions, and every other applicable deduction.
• A detailed list of the purpose for all potential pay period deductions.
• A listing of all allowances claimed as part of the minimum wage.
• A listing of all potential employer-provided benefits that may appear as contributions or deduction on the itemized statements.
• The Oregon Bureau of Labor and Industries (BOLI) will issue a forthcoming model written guidance document (in English, Spanish, and potentially other languages on request) that includes commonly used statewide deductions that employers may use and customize to satisfy these requirements. OR S.B. 906

Oregon Prescriptions

Authorization is granted to the use of third-party clearinghouses for the submission of 340B drug data which expands on the prior limited reliance on individual claim modifiers. A prohibition against 340B pharmacy discrimination in reimbursement rate practices, special fee assessments, and discount drug delivery method restrictions. The effective date shall be 91 days after the legislative session ends.

Rhode Island Health Insurance Rates

The Office of Health Insurance Commissioner (OHIC) released the premium rates for individual, small group, and large group markets. These rates are for effective coverage dates beginning on or after January 1, 2026. Small group market insurers requested an average increase of 22.2%, up from 20.3%. The large group market insurers requested an average increase of 26.4%, up from 13.5%.

Rhode Island Nonprofits

Nonprofits shall now disclose the total compensation packages of their five highest-paid employees who earn a minimum of $100,000. The total compensation packages are to include health insurance, retirement contributions and fringe benefits such as company cars and housing allowances. These disclosures shall not reveal the names of the five highest-paid employees.

Texas Health Insurance Provider Payments

Authorization has been granted for preferred provider and exclusive provider benefit plans designed to compensate primary care physicians through fee-for-service, risk-sharing, capitation, and hybrid arrangements. Enhanced requirements for the transparency of payment arrangements have been implemented. Going forward, contracts shall specify the way patients are assigned to physicians, with preference given to already existing doctor-patient relationships established from previous annual exams or patient elections. Capitated arrangement disclosures require that insurers detail the application of minimum payment guarantees, stop-loss coverage, and bridge rates.

Texas Unemployment Compensation

An expansion of worker rights to appeal state unemployment compensation decisions have been granted. Workers are permitted to submit their appeals to county courts or district courts rather than the previously limited option of filing in courts “of competent jurisdiction”.  Appeals must be filed no later than 14 days from the date the decision becomes final. The current expected effective date for this provision is September 1, 2025.

Texas Preauthorization

Health Maintenance Organizations and insurers shall no longer be permitted to require preauthorization for specific healthcare services when the treating physician or provider has maintained a 90% approval rate over the previous year and has also performed the service a minimum of five times during this period. This amendment removes the prior evaluation period requirement of every six months. Additionally, utilization reviews are to be conducted under the supervision of physicians licensed to practice medicine in Texas.

Texas Medical Records

Healthcare organizations shall be required to display instructions on their websites and at their facilities which explain patient access to their medical records and file complaints. The current expected effective date for this provision is September 1, 2025.

Vermont Prescriptions

Drug manufactures are restricted from denying or limiting discounted medication drug deliveries involving contract pharmacies that engage with 340B hospitals. Additionally, drug manufacturers shall no longer be permitted to require 340B entities to submit claims data or other information beyond federal regulatory requirements.

Vermont Medicare

Hospitals are required to accept payment amounts determined by the Green Mountain Care Board as a full payment. The Board payment determinations are based on a percentage of the Medicare rate or other permissible benchmarks. The current effective date for implementation is by hospital fiscal year 2027 with annual Board rate reviews.

Vermont Short-Time Compensation

Beginning on or before July 1, 2026, the Vermont Short-Time Compensation Program will be reinstated. The Program is designed to assist employers in avoiding layoffs during periods of reduced business activity and was previously ceased on July 1, 2020. Upon Vermont updating its unemployment insurance systems, the Program will be granted an official relaunch date.

Washington Unclaimed Wages

As of July 28, 2025, employers must file their unclaimed wages reports by October 31 of each calendar year. These reports are limited to amounts determined to be abandoned for a 12-month period prior to July 1 of the current calendar year. Additionally, as of January 1, 2026, employer unclaimed wage notices are to be issued for dollar amounts of $5 or more replacing the prior notice threshold of $50 or more. The aggregate report value is also amended to under $5 from the previous amount of under $50.

Wisconsin Hospital Care

The Wisconsin Department of Health Services issued a reminder to its residents that hospitals are required to provide lifesaving care for pregnancies under the Emergency Medical Treatment and Labor Act (EMTALA). Per EMTALA, the required care may include providing abortion care. Th reminder was issued following the June 3, 2025, Centers for Medicare and Medicaid Services (CMS) statement rescinding the July 2022 guidance on EMTALA enforcement as it relates to pregnancy.

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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.