The Washington Report
July 30, 2025
Note to Subscribers
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
Health
Illinois PBM Law Imposes New Fees and Conditions and Applies to Self-Insured Health Plans
On July 1, 2025, Illinois Governor JB Pritzker signed into law HB 1697 which expands existing state law applicable to pharmacy benefit managers (PBMs). The law is entitled the Prescription Drug Affordability Act (the Act). In addition to broadening Illinois’ already robust PBM law, the Act also imposes a new fee on PBMs to fund pharmacy grants. Though the Act is aimed primarily at PBMs, it does apply some of its requirements to fully insured and self-insured group health plans.
The Aon bulletin is available here.
IRS Announces 2026 Affordability Percentage for ACA Employer Mandate
On July 18, 2025, the Internal Revenue Service (IRS) announced that the required contribution percentage (RCP) used by employers for complying with the Affordable Care Act’s (ACA’s) employer mandate will be 9.96 percent for plan years beginning in calendar year 2026. This is an increase from the 2025 RCP, which was 9.02 percent.
The Aon bulletin is available here.
Retirement
Now Available: Legal Consulting & Compliance Quarterly Update
The Retirement Legal Consulting & Compliance practice is pleased to present its Quarterly Update of recent legal developments for the third quarter of 2025. In this issue you will find the following articles:
- Retiree Medical Surplus: Trap or Opportunity?
- The Prevalence of 401(k) Plan Data Issues
- DOL Modernizes Opinion Letter Program
- Ninth Circuit Rejects Claims that Intel Fiduciaries Acted Imprudently
- Quarterly Roundup of Other New Developments
The third quarter 2025 issue of the Retirement Legal Consulting & Compliance Aon Quarterly Update is available here.