Regulatory updates to watch in Q2 2026
These are the health care regulations, announcements and changes to keep on your radar for Q2 2026.
Staying on top of the legislative changes in an industry as complex and highly regulated as health care can be challenging.
That’s why UnitedHealthcare is committed to easing that burden and keeping employers updated on the legislative changes as they arise.
Here are 4 notices to watch in Q2:
2026 Prescription Drug Data Collection and Reporting
The Consolidated Appropriations Act of 2021 (CAA) requires health insurers and self-funded group health plans to submit annual Prescription Drug Data Collection (RxDC) to the Departments of Health and Human Services, Labor and the Treasury (Tri-Agencies).
UnitedHealthcare will handle Prescription Drug and Health Care Spending Reporting submissions for employers who:
- Had active coverage during the 2025 reference year
- Completed the Request for Information (RFI) by the March 31, 2026, deadline
The RFI collects information not available in UnitedHealthcare systems. UnitedHealthcare will provide the confirmation number once the data is submitted to CMS.
Important dates:
- May 15, 2026: Data delivery to self-funded customers who requested to file independently
- June 1, 2026: Deadline for UnitedHealthcare, or customers if self-reporting, to submit 2025 data under the RxDC program to CMS
Who it impacts: All fully insured, self-funded and level funded UnitedHealthcare customers, including Surest. United Medical Resources (UMR) will follow the UnitedHealthcare approach.
Out-of-pocket maximums announced for 2027
The 2027 out-of-pocket maximums will increase by 13.2% compared to 2026 levels, effective Jan. 1, 2027. The OOPM includes all copayments, deductibles and coinsurance for both medical and pharmacy benefits.
The 2027 OOPM for group health plans is outlined below:
| OOPM for 2026 plan year | OOPM for 2027 plan year | |
| Self-only | $10,150 | $12,000 |
| Family | $20,300 | $24,000 |
High deductible health plans (HDHPs) with health savings accounts (HSAs) follow different limits for OOPM, deductibles and contribution amounts.
Important dates:
- May 2026: Announcement of 2027 HDHP HSA limits
- Jan. 1, 2027: 2027 OOPM become effective
Who it impacts: This requirement applies to most non-grandfathered group health plans, whether fully insured or self-funded (ASO). It does not apply to grandfathered plans, transitional relief plans or retiree-only plans.
Medical Loss Ratio Early Warning Report
In June, UnitedHealthcare will provide fully insured employers and brokers an early read on which aggregation sets may receive an annual check due to Medical Loss Ratio (MLR). This applies to employers whose aggregation set (grouped by state, employer size and legal entity) qualifies for a rebate under the Affordable Care Act. An aggregation set qualifies when its MLR falls below 80% for small groups or 85% for large groups.
Important dates:
- June 15, 2026: MLR Early Warning Report will be available
- Sept. 30, 2026: Deadline for when employers scheduled to receive a rebate will receive their final report and check
Who it impacts: Fully insured health plans
Machine-readable files now in new Schema Version 2.0
UnitedHealthcare — including Surest® and UMR — has completed all required updates to comply with federal Transparency in Coverage (TiC) regulations for machine-readable files (MRFs) Schema Version 2.0. (This is a major update to health care MRFs designed to improve data quality, reduce file sizes and clarify provider information.) These updates went into effect with the February published files, ensuring continued compliance with TiC regulations for customers, brokers, consultants and regulators.
What's changed: All code updates are now in production and support the publication of 2026 machine-readable files. New files now include "Version" in the file to identify Schema Version 2.0.
What hasn't changed: File names and group health plan names remain the same. All files continue to be accessible through the same Transparency in Coverage public URL for fully insured and self-funded clients.
Who it impacts: All employers, brokers, consultants and regulators
Additional regulations we’re watching closely
- CAA final rule on air ambulance reporting – pending guidance
- CAA final rule for providing members with an advanced Explanation of Benefits (EOB) – pending guidance
- Final Transparency in Coverage Rule impacting machine-readable files and the consumer price transparency and cost estimate requirements.
- Final Independent Dispute Resolution Operations under No Surprises Act
- Patient-Centered Outcomes Research Institute (PCORI) fee due to IRS by July 31
- Gag clause confirmation of compliance for Q4 set to be released in Q3
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