Weekly Health Compliance Briefing

January 07, 2026

While we do our best to provide timely updates, it is possible that the information shared in the newsletter may change after our publication deadline.

Aon Publications

 

IRS Delays Enforcement of Certain PFML Tax and Reporting Obligations Until 2027
Internal Revenue Service (IRS) Notice 2026-6 gives states and employers one additional year to transition their systems to enable compliance with Revenue Ruling 2025-4 with respect to medical leave benefits paid under state Paid Family and Medical Leave (PFML) programs. The Notice does not provide an enforcement delay for tax and reporting requirements related to “employer pick up” contributions, which are amounts an employer voluntarily pays to cover all or a portion of a contribution an employee would otherwise be required to make to a state PFML program. Employers are required to treat 2026 “pick up” contributions as wages. 

The Aon bulletin is available here.

The All About Leave Newsletter—December 2025 Edition
The All About Leave Newsletter focuses on what employers need to know about state and local laws that regulate paid sick leave, paid family and medical leave, and paid leave for any reason

The December 2025 edition of the All About Leave Newsletter is available here.

Guidance Released on HSA Provisions Included in the One, Big, Beautiful Bill Act
On December 8, 2025, the Department of Treasury and the Internal Revenue Service issued Notice 2026-5 providing guidance on the Health Savings Account (HSA) provisions that were included in the One, Big, Beautiful Bill Act (OBBB) enacted last summer. Notice 2026-5 provides new guidance on the expanded HSA provisions included as part of the OBBB, it provides details on HSA-compatible plans’ ability to offer telehealth and remote care services before the deductible has been met, and it also includes guidance addressing when an individual who is covered under a qualified Direct Primary Care Service Arrangement continues to be eligible to contribute to an HSA.

The Aon bulletin is available here.