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Key Effective Dates for Benefits-Related Provisions in OBBB
Upcoming Benefit & Policy Changes
Provision |
Effective Date |
Expanded HSA eligibility
Note: Includes bronze/catastrophic plans; excludes Medicare Part A
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Jan 1, 2026 |
Telehealth pre-deductible (HDHP)
Note: Retroactive from Dec 31, 2024
|
Jan 1, 2025 |
Tax-free student loan repayment
Note: Section 127 expansion; indexed
|
Jan 1, 2026 |
Trump Accounts
Note: $5K/year; employer match up to $2.5K
|
Jan 1, 2025 |
Dependent Care FSA increase
Note: Raised to $7.5K (not indexed)
|
Jan 1, 2026 |
Childcare credit expansion
Note: Up to 50% credit; $500Kâ600K max
|
Jan 1, 2026 |
Medicaid & SNAP reforms
Note: Work requirements, verification updates
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2026â2028 |
(HRA-to-HSA and ICHRA flexibility were removed from the final bill.)
Benefits Admin Action Items
- Review documents with TPAs by Q4 2025
- Prep open enrollment comms for 2026
- Coordinate payroll + compliance for updated tax rules
- Consider offering Trump Accounts + Dep-Care FSA
- Track Medicaid/SNAP reforms for impact on hourly workforce.
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In this issue:
This Just In ... Employers Shift Focus from Expanding Benefits to Extracting More Value
New Compliance Rules Ahead: What the OBBB Means for Your Benefits Team
AI-Powered Benefits Administration: The Next Frontier in HR Efficiency
Mental Health Parity Compliance: What Employers Need to Know in 2025
Key Effective Dates for Benefits-Related Provisions in OBBB
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