Weekly Health Compliance Briefing
June 10, 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.
Health Notes
DOL Announces no Adjustments to Civil Penalty Amounts for 2026
The Department of Labor (DOL) has announced that there will be no 2026 annual adjustments to civil monetary penalties for certain benefit-related violations. Affected penalties cover a wide range of issues, including (i) Form 5500 and Form M-1 filing failures, (ii) failures relating to the summary of benefits and coverage, (iii) violations of the Genetic Information Nondiscrimination Act, and (iv) failures relating to disclosures regarding the availability of Medicaid or Children’s Health Insurance Program assistance.
Under the 2015 legislation that requires annual inflation adjustments for specified civil penalty amounts, the adjustments are to be calculated using the Consumer Price Index for All Urban Consumers issued by the Bureau of Labor Statistics (BLS) for the prior October. However, due to the federal government shutdown that occurred during the fall of 2025, BLS was unable to produce the October 2025 data needed to calculate the 2026 penalty adjustments. Because the statute does not provide an alternate method for calculating the adjustments, the director of the Office of Management and Budget has cancelled the 2026 penalty adjustments and directed agencies to continue using the 2025 penalty amounts. This announcement provides clarity regarding the 2026 penalty adjustments, which are normally announced every January.
Aon Publications
IRS Announces HSA (as Well as DPCSA and EB HRA) Limits for 2027
On May 29, 2026, the Internal Revenue Service (IRS) issued Revenue Procedure 2026-24, which announced the inflation-adjusted limits for Health Savings Account (HSA) contributions for the 2027 calendar year, as well as the minimum deductible amounts and maximum out-of-pocket limits for HSA-qualifying High-Deductible Health Plans.
The Revenue Procedure also announced the inflation-adjusted limits for Direct Primary Care Service Arrangement (DPCSA) fees for the 2027 calendar year and for Excepted Benefit Health Reimbursement Arrangements (EB HRAs) for the 2027 plan year.
Employer plan sponsors should incorporate these new limits into their 2027 planning cycle.
The Aon bulletin is available here.