Compliance Calendar — upcoming deadlines

Jul 31	PCORI fee due (Form 720) for self-insured health plans
Jul 31	Form 5500 due for calendar-year plans (without extension)
Dec 31	Gag-clause prohibition compliance attestation (GCPCA) due

Today’s Briefing

JPMorgan ERISA drug-benefit class action clears motion to dismiss

Buchanan Ingersoll & Rooney

In Stern v. JPMorgan Chase & Co. (S.D.N.Y.), the court let ERISA prohibited-transaction claims over the plan’s PBM arrangement proceed, with plaintiffs leaning on a recently lowered pleading standard. The ruling signals that prescription-drug fee claims can now survive early dismissal — a warning for plan sponsors.

Read at Buchanan Ingersoll & Rooney →

Agencies won’t defend 2024 MHPAEA final rule, plan replacement regs

DOL EBSA · tri-agency statement

In a March 30, 2026 court filing, the DOL, HHS, and Treasury said they will no longer defend the 2024 mental health parity final rule and intend to propose replacement regulations by year end. Nonenforcement continues — but plans must still perform and document the NQTL comparative analysis.

Read at DOL EBSA →

PBM trade group challenges California PBM-fiduciary law as ERISA-preempted

Trucker Huss

A PBM trade association is challenging the fiduciary provisions of a new California law as preempted by ERISA. The case tests how far states can regulate PBMs that serve self-funded plans, and could shape the compliance landscape for plan sponsors nationwide.

Read at Trucker Huss →

Government Guidance & Regulatory Activity

IRS	Rev. Proc. 2026-24 — 2027 HSA/HDHP & EBHRA limits (HSA $4,500 self / $9,000 family). Informational.
EBSA	Tri-agency statement — MHPAEA 2024 final rule nonenforcement; replacement rulemaking anticipated. Comparative-analysis duty unchanged.

The Docket

Litigation to watch: Stern v. JPMorgan (S.D.N.Y.) — prohibited-transaction claims survive dismissal · Lewandowski v. J&J (D.N.J.) — dismissed Jan. 2026 for lack of standing, on appeal to the Third Circuit.

Rulemaking ahead: DOL/HHS/Treasury signaled replacement MHPAEA regulations to be proposed by the end of 2026.

Recurring deadlines: PCORI & Form 5500 (Jul 31) · Gag-clause attestation (Dec 31).

Sources: Buchanan Ingersoll & Rooney · DOL EBSA · Trucker Huss · IRS / Journal of Accountancy · CMS. Compiled from the day’s benefits feeds; reviewed before publication.