June 2026: Employee Benefits Compliance Brief
An exclusive UBA Partner Firm monthly newsletter, focusing on one of your most important responsibilities — employer compliance.
Employer Priorities
IRS Releases 2027 HSA, HDHP, and Excepted-Benefit HRA Limits
The IRS has announced the 2027 inflation-adjusted limits for health savings accounts (HSAs), high-deductible health plans (HDHPs), and excepted-benefit health reimbursement arrangements (HRAs). These updates provide employers with an opportunity to begin evaluating benefit strategies, budgeting for employer HSA contributions, and preparing open enrollment communications.
Employers offering HSA-qualified plans should remember that IRS HDHP requirements differ from ACA out-of-pocket maximum limits, requiring compliance with both sets of rules where applicable.
Employer Considerations:
- Review 2027 HDHP plan designs for compliance with IRS requirements
- Update payroll systems and employee communication materials
- Evaluate employer HSA contribution strategies and budget impacts
- Monitor future ACA cost-sharing limit guidance from CMS and HHS
PCORI Fees Due July 31
Employers sponsoring self-insured health plans, including level-funded plans and HRAs, may be required to report and pay Patient-Centered Outcomes Research Institute (PCORI) fees by July 31, 2026. For plan years ending in 2025, fees range from $3.47 to $3.84 per covered life, depending on the plan year end date.
Many employers mistakenly assume level-funded plans are fully insured; however, employers generally remain responsible for PCORI fee reporting and payment.
Employer Considerations:
- Confirm whether your organization sponsors self-insured coverage
- Determine responsibility for filing Form 720
- Calculate covered lives using an IRS-approved method
- Submit Form 720 and payment by July 31
Summary of Material Modifications Due July 29
Calendar-year health plans that adopted material plan changes during the 2025 plan year may need to distribute a Summary of Material Modifications (SMM) by July 29, 2026. The SMM informs participants of significant changes affecting benefits, eligibility, claims procedures, or other plan provisions.
Employers that have already distributed an updated Summary Plan Description (SPD) reflecting these changes may not need to provide a separate SMM.
Employer Considerations:
- Review plan amendments adopted during 2025
- Confirm whether updated SPDs have already been distributed
- Prepare and distribute required SMMs by July 29
- Maintain documentation of participant disclosures
Form 5500 Deadline Approaching for Calendar-Year Plans
For calendar-year group health plans required to file Form 5500, the filing deadline is July 31, 2026. Employers needing additional time may request an extension by filing Form 5558, extending the deadline to October 15.
Generally, group health plans with 100 or more participants at the beginning of the plan year are subject to filing requirements, although certain exemptions may apply.
Employer Considerations:
- Confirm whether your plan is required to file
- Gather necessary plan and participant information
- Coordinate filing responsibilities with service providers
- File Form 5558 if additional time is needed
Question of the Month
Missed Form 5500 Filings
Q. A client recently discovered they have never filed Form 5500 for a plan that may have been subject to filing requirements. How far back should they go when correcting missed filings?
A. Employers should consider utilizing the Department of Labor’s Delinquent Filer Voluntary Compliance Program (DFVCP). The program allows employers to correct missed filings while significantly reducing potential penalties. Employers should file for all years in which a filing obligation existed and provide the most complete information available. The DOL has historically demonstrated flexibility for employers making a good-faith effort to come into compliance through the program.
Relational Advisors is a UBA Partner Firm.