Matthew A. Criswell

The One Big Beautiful Bill (OBBB), signed into law on July 4, 2025, delivers significant updates to employee benefits. Most notably, it expands HSA eligibility, increases dependent care FSA limits (finally!), makes permanent student loan repayment assistance, solidifies paid family and medical leave employer tax credits, includes updates for measuring executive compensation taxable caps, and introduces employer contributions to “Trump Accounts” (i.e., investment accounts for children). Below is a breakdown of these updates that could significantly affect how employers offer employee benefits in the years ahead.  

The Mental Health Parity and Addiction Equity Act (MHPAEA) requires group health plans to provide mental health and substance use disorder (MH/SUD) benefits equal to medical/surgical benefits. In September 2024, federal agencies issued the 2024 MHPAEA Final Rule, introducing new compliance requirements with effective dates beginning January 1, 2025.  

Making several changes, the IRS has released the 2023 cost-of-living adjustments applicable to the dollar limits and thresholds for retirement plans and health and welfare benefit plans. Plan sponsors should update their systems and formulas to include the limits that have been adjusted.  

The Securities and Exchange Commission (“SEC”) recently proposed rule changes applicable to public companies to enhance and standardize disclosures concerning cybersecurity risk management, strategy, governance, and cybersecurity incident reporting. The proposed rules would amend rules regarding current and periodic reporting requirements. These proposed amendments are intended to better inform investors about a registrant’s risk management, strategy, and governance and to provide timely notification of material cybersecurity incidents.