The Washington Report
August 13, 2025
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The Washington Report will not be published on August 20, 2025. Look for your next Aon Washington Report on Wednesday, August 27, 2025
Legislative
Congress Adjourned for Summer Recess
Congress has adjourned for its summer recess. The House and Senate are scheduled to reconvene after the Labor Day holiday.
Health
Departments Signal a Shift in Enforcement of Short-Term Health Insurance Rules
The Departments of Labor, Health and Human Services (HHS), and the Treasury (the Departments) announced on August 7, 2025, that they are reconsidering the definition of “short-term, limited-duration insurance” (STLDI) through a formal rulemaking process. The statement makes it clear that until new regulations are finalized, the Departments will not prioritize enforcement actions against insurers that do not fully comply with the 2024 definition (including related notice requirements). In addition, HHS is also encouraging states to adopt a similar enforcement approach and will not penalize states that either follow this federal approach or apply their definitions of STLDI under state law.
The Departments’ announcement is available here.
DOL Asks for Comments to Review Information for Special Enrollments
The Department of Labor (DOL) is requesting information regarding what employer-sponsored group health plans tell employees about special enrollment rules when they initially decline enrolling in the plan. The DOL’s information collection request seeks details on how health plans implement Section 701(f) of ERISA, which provides special enrollment rights after specified events (such as the death of a spouse or birth of a child) to those who previously declined group health plan coverage. Under ERISA, plans and issuers are required to provide a 30-day period following events to give eligible, uncovered individuals the chance to enroll. A group health plan may require that employees who initially decline coverage provide the plan with a written statement declaring whether they are doing so because they have other coverage as a precondition to later allowing them special enrollment participation. The regulations establish that the right to special enrollment can only be denied if employees are given notice of the requirement for a written statement and the consequences of failing to provide it at the time an employee initially declines coverage. Employees’ failure to provide a written statement can eliminate their right to special enrollment upon losing eligibility for such other coverage, according to the notice. Now, comments from stakeholders are invited on the following issues: (i) whether the collection of information is necessary for the proper performance of the functions of the Department, including whether the information will have practical utility; (ii) the accuracy of the agency's estimates of the burden and cost of the collection of information, including the validity of the methodology and assumptions used; (iii) ways to enhance the quality, utility, and clarity of the information collection; and (iv) ways to minimize the burden of the collection of information on those who are to respond, including the use of automated collection techniques or other forms of information technology. Comments should be submitted in writing on or before 30 days after publication in the Federal Register.
The DOL’s information collection request is available here.