ACA Compliance Lessons Learned From Recent Reporting Seasons
Common themes emerge when reflecting on recent ACA reporting seasons that can help employers reduce administrative burdens and improve accuracy.
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While much of the attention on the new legislation has focused on tax reform and spending provisions, the nearly 900-page bill also includes several significant updates impacting
Signed into law on July 4, 2025, the wide-ranging “One Big Beautiful Bill Act” (OBBB) introduces major changes across the employee benefits landscape that will significantly impact employers and HR teams. From dependent care and paid leave to student loan assistance and the creation of new “Trump Accounts,” this legislation brings both new opportunities and new responsibilities for employer-sponsored plans.
Most of the changes impacting employee benefits go into effect for tax years beginning after** **December 31, 2025 (i.e., in 2026).
Here’s what HR professionals need to know.
** Dependent Care FSAs and Tax Credits Expanded** Beginning in 2026, the annual income exclusion for Dependent Care Assistance Programs (DCAPs) increases from $5,000 to $7,500 (or $3,750 for those married filing separately). While not indexed for inflation, this higher cap offers greater flexibility for employees with childcare expenses. Additionally, the Dependent Care Tax Credit (DCTC), a benefit for employees, has been enhanced, offering a higher maximum credit rate and a more favorable phaseout schedule. Separately, employers benefit from an expanded employer-provided childcare tax credit (for those employers who provide or support childcare services for employees), which now allows a credit of up to $500,000 (adjusted annually) and covers 40% of qualified childcare expenditures (increased from 25%).
** Health Savings Accounts (HSAs): Telehealth and DPC Reforms** Several permanent HSA-friendly provisions take effect: Telehealth: HDHPs may now permanently cover telehealth services before the deductible is met. This rule is retroactive to plan years beginning after 2024. Employers who charged employees for early-year telehealth visits under an HDHP will have to decide whether to reimburse these charges
Direct Primary Care Arrangements: Starting in 2026, individuals enrolled in qualifying Direct Primary Care (DPC) arrangements will no longer be excluded from HSA-eligibility, provided monthly fees do not exceed $150 for individuals or $300 for families.
Marketplace Plan Eligibility: ACA Exchange bronze and catastrophic plans will qualify as HDHPs for HSA purposes beginning January 2026, expanding HSA access for individual plan enrollees.
** Paid Family and Medical Leave Credit Made Permanent** The Section 45S tax credit for employers offering paid family and medical leave has been permanently extended. Starting in 2026, employers may apply the credit to premiums paid for insured paid leave policies and the minimum employment requirement is reduced from one year to six months. This expanded credit is now available in all states.
** Employer Student Loan Repayment Assistance Extended** Employers may now permanently offer up to $5,250 annually in tax-free student loan repayment assistance through educational assistance programs. Starting in 2027, the cap will be indexed for inflation, making it a potential tool for talent retention.
** Introducing “Trump Accounts” for Minors** New Trump Accounts, a tax-advantaged custodial account similar to IRAs, are now available for children under 18 with a Social Security number. Employer Contributions: Employers may contribute up to $2,500 annually (adjusted for inflation) per eligible employee or their dependent.
Employee Contributions: Combined family contributions may total up to $5,000** **annually.
Pilot Program: For children born between 2025 and 2028, the government will contribute a one-time $1,000 seed deposit.
Withdrawals are restricted until the beneficiary turns 18, and investments must follow guidelines similar to retirement accounts.
This legislation represents one of the most substantial benefits reforms in recent years. Employers should be aware of the provisions impacting employee benefits.
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This article is for informational purposes only and is not intended as legal, tax, or benefits advice. Readers should not rely on this information for taking (or not taking) any action relating to employment, compliance, or benefits. Always consult with a qualified professional before making decisions based on this content.