Two smart compliance moves to make this month
As you’re juggling rising healthcare costs, retention challenges and an ever-shifting regulatory environment, the last thing you need is more confusion.
That’s why two recent changes to federal reporting requirements are worth your attention. One offers a practical way to reduce administrative overhead. The other requires a specific action by mid-February to avoid noncompliance.
A more efficient approach to Form 1095-C distribution
If your health plan covers more than 50 employees, your organization still needs to electronically file Forms 1094-C and 1095-C with the IRS by March 31, 2026 — that hasn’t changed. But for the 2025 reporting year, you’re no longer required to automatically mail copies of the Form 1095-C to every employee.
Instead, you can shift to an on-request system:
- Post a notice on your external website (not intranet) by Jan. 31, 2026, explaining that employees can request their form if needed.
- Provide the form within 30 days when an employee submits a written request.
- Continue working with your payroll provider for IRS filing as usual.
This isn’t a massive overhaul, but it’s a straightforward way to cut printing and mailing costs while maintaining full compliance. Your payroll provider will still handle IRS filing as usual.
Remember, the decision is yours. Some might prefer the simplicity of continuing their current process, while others may desire the cost savings and reduced administrative work. Both options are compliant!
HIPAA notice updates that need your attention
If your organization sponsors a group health plan, your HIPAA privacy notices may need updating in two specific areas:
- Add consent language for substance use disorder by Feb. 16: Your HIPAA notices must now include specific consent requirements before any individually identifiable health information related to substance use disorders can be disclosed. This change strengthens privacy protections in an area where employees are particularly vulnerable. The deadline on Feb. 16, 2026, is firm, so if you haven’t addressed it yet, now is the time.
- Remove outdated reproductive healthcare provisions: Special disclosure protections that were added under previous federal guidance are no longer in effect. If your notice includes these provisions, take them out.
Moving forward
These updates won’t transform your benefits operation, but they matter. The Form 1095-C change gives you an opportunity to improve efficiency. The HIPAA updates ensure you’re protecting employee privacy in the way federal law now requires.
Both reflect something larger: compliance isn’t static. Regulations evolve, and staying current protects both your organization and your people.
If you’re unsure whether your current notices need modification, or if you want to discuss the best approach for Form 1095-C distribution, we can help. That’s what we’re here for.
Please reach out if you have questions. We’re happy to support you in making compliance as straightforward as possible.
Content sponsored by Sandberg Phoenix law firm. This update is not intended to be exhaustive, nor should any discussion or opinions be construed as legal, tax or financial advice. TrueNorth Companies recommends consulting with legal, tax or benefits professionals before making any decisions related to employee benefit plans.
