The Washington Report

December 10, 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.

Health

 

Reminder: Required ACA Preventive Care Coverage Expands in 2026
The Affordable Care Act (ACA) requires non-grandfathered group health plans (GHPs), whether fully insured or self-insured, to cover certain in-network preventive care without cost-sharing. The required preventive care includes services given an “A” or “B” rating from the U.S. Preventive Services Task Force (USPSTF), vaccines recommended by the Advisory Committee on Immunization Practices, and preventive care and screenings for children and women recommended by the Health Resources and Services Administration (HRSA). If there are changes in recommendations or guidelines, GHPs generally must provide coverage for plan years that begin one year after the change. For example, a change recommended in December 2024 would take effect in plan years beginning in 2026.

This is a reminder that GHP sponsors should be aware of the expanded breast cancer screening benefits that are scheduled to take effect in 2026. More specifically, updated HRSA Women's Preventive Services Guidelines broadened the range of breast cancer screening benefits that are covered as preventive care. Currently, ACA guidelines require GHPs to cover routine screening mammograms for women at average risk of breast cancer starting at age 40, at least biennially and as frequently as annually.

Effective for plan years beginning in 2026, the coverage must also include:

• Additional imaging services (e.g., ultrasounds or MRIs) when medically indicated, and pathology services (e.g., a needle biopsy), if necessary to complete the screening process for malignancies or address findings on the initial mammography.
• Patient navigation services for breast and cervical cancer screening and follow-up to increase use of screening recommendations based on the patient's need for such services.

“Navigation services” would include patient assessment and care planning, referrals to supportive resources (e.g., transportation, language translation, and social services), patient education and coaching, as well as health care access and system navigation. These services should be individualized to the patient and can be provided in person and/or virtually. According to the HRSA, navigation services have proven to lead to earlier cancer detection, and to improved screening rates and treatment outcomes.

Note that the 2026 HRSA updates are in addition to existing USPSTF-recommended preventive services, which include breast cancer susceptibility gene (BRCA) screening, genetic counseling, and testing, if appropriate for a woman as determined by her health care provider (e.g., based on a prior breast cancer diagnosis or family history associated with an increased risk of BRCA-related cancer). The USPSTF guidelines also include coverage of risk-reducing prescription medications for certain women at increased risk for breast cancer, when prescribed by clinicians.

GHP sponsors should confirm updates to plan systems, documents, and participant communications with their carriers, third-party administrators, and other service providers to implement these updated preventive care requirements. Employers may also want to discuss any potential impact to their budget resulting from the expanded recommendations. Employers should do so to monitor preventive services guidelines generally, since there have been changes at the government agencies that make the recommendations as well as pending litigation challenging aspects of the ACA preventive services mandate.

Aon Publications

 

2026 Limits for Benefit Plans
Each year, the U.S. government adjusts the limits for retirement plans, Social Security, Medicare, and other benefit programs to reflect price and wage inflation, and changes in the law. As a result, employee benefit plans must be adapted annually to accommodate the new limits. All of the numbers in this report are official unless otherwise indicated.

The 2026 Limits for Benefit Plans bulletin is available here.