2025 Regulatory Highlights for Health Plans, PBMs and TPAs: A Year in Review from Regulatory Joe

2025 has been a defining—and often complicated—year for regulatory compliance across health plans, PBMs and TPAs. From shifting federal rules to expanding state oversight, each month brought new questions for teams navigating ACA operations, licensure, filings and market strategy.

As we wrap up the year, we’ve pulled together a recap of every Regulatory Joe episode from 2025 to help you look back at the key insights, practical guidance and real-world considerations that shaped our conversations. Whether you’re reviewing your compliance roadmap or preparing for 2026, this reflection can help you and your teams stay informed and ready for what’s next.

Episode 1 of 2025: SBM-FPs – Aired January 13, 2025

State-based marketplaces operating on the federal platform are reshaping how states manage ACA operations, and Joe explains what this shift means for carriers navigating new state-specific requirements, operational changes and member communication needs.

Episode 2 of 2025: Risk Adjustment – Aired January 29, 2025

Risk adjustment in 2025 brings major shifts—from a new CMS baseline dataset to changes in user fees and AI/AN reporting expectations—and Joe outlines how issuers can strengthen operational readiness and data coordination to stay compliant and financially stable.

Episode 3 of 2025: Breaking Down the 2026 NBPP – Aired February 19, 2025

The 2026 NBPP introduces several high-impact regulatory updates, and Joe breaks down what these changes mean for plan design, pricing and compliance while outlining clear next steps for issuers.

Episode 4 of 2025: MPMS Plan and Benefit Justification – Aired March 12, 2025

CMS’s move to generate Plan and Benefit Justification Forms within MPMS fundamentally changes the submission process, and Joe explains how issuers can tighten validation, strengthen version control and manage post-submission risk.

Episode 5 of 2025: Reconciliation & Validation – Aired April 2, 2025

Reconciliation and validation are now core determinants of ACA filing success, and Joe explains how issuers can manage evolving CMS tools, AV updates and internal workflows heading into 2026.

Episode 6 of 2025: Preventing Pharmacy Benefit Template Objections (feat. Bryan Connole) – Aired April 16, 2025

As pharmacy benefit templates face increased scrutiny, Joe and Bryan Connole, Director of Plan Management at ClearFile, outline the validation tools, cross-template checks and coordination needed to avoid objections and rework.

Episode 7 of 2025: What’s Next for APTCs and CSR Funding? (feat. Jeff Grant) – Aired June 18, 2025

Joe and Jeff Grant, former Deputy Director of Operations at CCIIO and now President of Schedule F Healthcare Strategies, unpack how uncertainty around APTCs, CSR funding and silver loading is shaping issuer strategy for 2026.

Episode 8 of 2025: Inside the ACA Investment Playbook – Aired June 25, 2025

Joe walks through why ACA growth remains a timely opportunity and the strategic investments—from networks to operations and competitive intelligence—that support scalable expansion.

Episode 9 of 2025: Staffing Your Health Plan for ACA Success – Aired July 2, 2025

Staffing models have become critical to ACA performance, and Joe explains when role-based versus market-based approaches make sense as filing work grows more complex and continuous.

Episode 10 of 2025: PBM Licensure 101 – Aired July 16, 2025

PBM licensure has evolved into a complex regulatory requirement, and Joe breaks down what PBMs must understand about state variation, rising costs and ownership to stay compliant and ready to grow.

Episode 11 of 2025: The Proactive PBM (feat. Mallory Mojarro) – Aired July 30, 2025

Joe and Mallory Mojarro, Manager of Licensing and Regulatory Compliance at True Rx Health Strategists, explain why proactive licensure management, centralized tracking and cross-team coordination are now strategic advantages for PBMs.

Episode 12 of 2025: How Health Plans Can Prepare for a Shortened OEP – Aired August 13, 2025

A permanently shortened 2026 Open Enrollment window will reshape member behavior and operational timelines, and Joe outlines the steps issuers should take now to protect membership and capture growth.

Episode 13 of 2025: The Big ACA Reset (feat. Wesley Sanders) – Aired August 21, 2025

Joe and Wesley Sanders, founder of Evensun Health, explore how subsidy changes and shorter enrollment periods could redefine ACA market stability and retention strategies in 2026.

Episode 14 of 2025: TPA Licensure 101 – Aired September 3, 2025

TPA licensure often hides complexity beneath the surface, and Joe explains how administrators can avoid surprises by centralizing filings, planning early and confirming regulatory expectations.

Episode 15 of 2025: Your ACA Compliance Toolkit

Joe highlights the core tools issuers need—from regulator engagement to filing technology and reporting infrastructure—to reduce objections and improve speed to market.

Episode 16 of 2025: ACA Compliance for Employers and Brokers (feat. Jordan O. Smith) – Aired October 8, 2025

Joe and Jordan O. Smith, Practice Leader at Lumelight, break down why ACA compliance remains high-risk for employers and brokers as IRS enforcement becomes faster and more automated.

Episode 17 of 2025: The Evolving TPA Landscape (feat. Jennifer S. Berman) – Aired October 30, 2025

Joe and Jennifer S. Berman, Chief Legal Officer at Lumelight, discuss how operational excellence, training and regulatory vigilance are defining the next phase of TPA leadership.

Episode 18 of 2025: Risk Adjustment in a Post-Subsidy Market – Aired November 19, 2025

Joe explains how a potential end to enhanced APTCs could reshape the risk pool and disrupt transfers beginning in PY2027—and what issuers should be doing now to prepare.

Episode 19 of 2025: MCAS 101 – Aired December 3, 2025

MCAS offers regulators a clear view into plan operations, and Joe outlines how year-round readiness can reduce audit risk and keep submissions defensible.

Looking Forward to 2026

Thanks for tuning in to Regulatory Joe in 2025! It’s been a fast-moving year, and we’re grateful for everyone who tuned in, shared episodes with colleagues, or used these discussions to support their work.

A heartfelt thank-you as well to the incredible guests who joined the show: Jennifer S. Berman, Jordan O. Smith, Jeff Grant, Wesley Sanders, Mallory Mojarro, and Bryan Connole. insight and willingness to share real-world experience added so much value for our viewers.

We’re looking ahead to 2026 with appreciation and momentum, ready to keep exploring the all things regulatory compliance in the new year.

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