Starting with plan years on or after January 1, 2026, several key updates to women’s preventive health services under the Affordable Care Act (ACA) will take effect. These are more than just regulatory tweaks, they may impact your health plan design, costs, and vendor relationships, especially if you sponsor a self-funded or level-funded plan.
Quick Background
The ACA requires non-grandfathered health plans to cover certain preventive services in-network and at no cost to participants. When guidelines are updated, plans must comply starting with the first plan year that begins one year after the update’s publication. In this case, the December 2024 updates must be implemented in 2026.
What’s Changing for 2026
1. Expanded Screening for Intimate Partner Violence
Plans must now cover or refer for ongoing intervention services, not just an initial one. This change could increase utilization and may require coordination with community or behavioral health resources.
2. Enhanced Breast Cancer Screening
If a screening mammogram indicates a potential issue, plans must cover:
- Additional imaging (MRI, ultrasound, or repeat mammogram)
- Pathology evaluations
These follow-ups must now be covered in full as part of preventive care, representing a new cost exposure, especially for self-funded plans.
3. New: Patient Navigation Services
Plans must cover individualized support to help patients navigate breast and cervical cancer screenings and follow-ups. Services include:
- One-on-one guidance (in-person or virtual)
- Assistance with referrals, transportation, translation, and education
Not all carriers or TPAs may currently offer this, so employers should confirm availability ahead of 2026.
Compliance Matters
Non-compliance could result in:
- $100 per person, per day penalties
- Required retroactive reimbursements to affected participants
What Employers Should Do Now
- Meet with your carrier or TPA to confirm their implementation plans, especially for patient navigation services.
- Review your plan design and budget if you’re self-funded; additional imaging may raise costs.
- Educate your employees about these enhanced services, highlight the value of early detection and no-cost access to care.
Final Takeaway
These ACA updates are designed to make women’s preventive care more accessible, comprehensive, and supportive. As an employer, staying ahead of these changes ensures compliance, cost control, and better health outcomes for your workforce.