The Washington Report

November 05, 2025

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 Issues Adjusted PCORI Fee for Plan Sponsors
On November 3, 2025, The Internal Revenue Service (IRS) issued Notice 2025-61 announcing the applicable Patient-Centered Outcomes Research Trust Fund (PCORI) fee for plan years that end on or after October 1, 2025, and before October 1, 2026 (e.g., the applicable PCORI fee for 2026 calendar year plans). The PCORI fee for 2026 was increased to $3.84 per covered individual (up from $3.47 in 2025). Plan sponsors will need to pay the required fee to the IRS by July 31, 2026.

The Aon bulletin is available here.

PBM Legislation Signed Into Law in California
On October 11, 2025, California Governor Gavin Newsom signed into law S.B. 41 regulating pharmacy benefit managers (PBMs). Although certain restrictions under the new law may not apply directly to self-insured plans, there may be practical implications for self-insured plans as the law is implemented and PBMs look to address new restrictions across their books of business in California. 

One key provision imposes a fiduciary duty on PBMs with respect to their self-insured employers under state law, thereby raising ERISA preemption issues. Employers with group health plans in California should talk to their PBMs about any changes their PBMs may make in plan design or administration, and any accompanying costs. 

The Aon bulletin is available here.