A new chapter begins

Some states require group health plan sponsor reporting 

December 3, 2025

Group health plan sponsors (GHP) continue to face myriad state and city reporting and individual health coverage disclosure requirements as summarized in this GRIST. These reporting requirements basically fall into three categories: individual health coverage mandates, health plan covered-lives assessments/surcharges and other health plan sponsor reporting. As a reminder, ERISA arguably preempts some, but not all, state reporting requirements for GHP sponsors, but there are no current legal challenges to these employer mandates. This GRIST has been updated to reflect state implications resulting from the federal Paperwork Burden Reduction Act.

Download the print-friendly PDF to read the full 20-page update.

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