In this Alert, we address questions related to the December 31, 2025, expiration of the ACA Marketplace enhanced subsidy, and provide guidance for employers. Applicable Large Employers (ALEs) remain subject to the ACA's employer mandate and must offer health plan coverage that is affordable and of minimum value to full time employees or risk significant tax penalties. There is no Section 125 qualifying life event (QLE) related to the expiration of these enhanced subsidies to allow employees to join an employer’s group health plan mid-plan year.
This Alert is relevant for employers who offer employees pre-tax group health plan coverage and ALEs.
