CAA 2026: The Complete Employer Guide
CAA 2026: The Complete Employer Guide
The most comprehensive employer guide to the Consolidated Appropriations Act of 2026 — 18 modules covering PBM reform, employer fiduciary duties, self-funded plan impact, MHPAEA, price transparency, enforcement, and a 12-month compliance roadmap.
What You Will Learn
Learning objectives for this course.
Who This Course Is For
This course is designed for the following roles.
Course Modules
18 modules · 18 lessons
What Is the CAA 2026? Legislative Overview
Understand what the Consolidated Appropriations Act of 2026 is, what it covers, and why it represents the most significant employer health plan legislation since the ACA.
1 lessons · 8 min
Legislative History: From CAA 2021 to CAA 2026
Trace the legislative arc from the ACA through the CAA 2021 and into the CAA 2026, understanding why each wave of reform built on the last and what gaps Congress was trying to close.
1 lessons · 9 min
Employer Fiduciary Duties Under CAA 2026
Understand the expanded ERISA fiduciary framework the CAA 2026 creates for employer plan sponsors — what it requires, what it prohibits, and what personal liability it creates for plan fiduciaries who fail to act.
1 lessons · 11 min
PBM Reform: Core Prohibitions and Mandates
Master the core PBM prohibitions and mandates in the CAA 2026 — what PBMs can no longer do, what they must now disclose, and how these changes reshape the pharmacy benefit management landscape for employer-sponsored plans.
1 lessons · 12 min
Spread Pricing: Definition, Prohibition, and Enforcement
Understand exactly what spread pricing is, how PBMs used it to extract billions from employer plans, what the CAA 2026 prohibition requires, and how employers can verify compliance.
1 lessons · 10 min
Formulary Transparency and Drug Pricing Disclosure
Understand the CAA 2026 formulary transparency requirements — what PBMs must disclose about formulary design, drug tier placement, and pricing — and how employers can use this information to protect plan participants.
1 lessons · 9 min
PBM Contract Obligations: What Employers Must Now Require
Learn exactly what the CAA 2026 requires employers to include in PBM contracts — the specific provisions, audit rights, pass-through guarantees, and termination rights that every compliant PBM agreement must contain.
1 lessons · 11 min
Rebate Reform: Pass-Through Requirements and Point-of-Sale Rebates
Understand the CAA 2026 rebate reform provisions — mandatory pass-through of manufacturer rebates, point-of-sale rebate requirements, and how employers can ensure rebates are reducing plan costs rather than enriching PBMs.
1 lessons · 10 min
PBM Accreditation, Audits, and Oversight
Understand the CAA 2026 PBM accreditation requirements, what federal oversight standards PBMs must now meet, and how employers can use audit rights and oversight tools to hold their PBM accountable.
1 lessons · 9 min
Impact on Self-Funded Health Plans: What Changes Now
Understand the direct and specific impact of the CAA 2026 on self-funded employer health plans — what changes immediately, what phases in, and what self-funded employers must do differently starting now.
1 lessons · 11 min
TPA Obligations and Employer Oversight Duties
Understand what the CAA 2026 requires of third-party administrators, what new oversight duties it places on employers, and how to structure the TPA relationship to ensure compliance and protect plan participants.
1 lessons · 10 min
Cost Containment Strategies Unlocked by CAA 2026
Discover the specific cost containment strategies that the CAA 2026 makes possible — from pass-through pricing and rebate optimization to formulary redesign and PBM competition — and how to implement them.
1 lessons · 10 min
Mental Health Parity: MHPAEA Strengthened Under CAA 2026
Understand how the CAA 2026 strengthens the Mental Health Parity and Addiction Equity Act — what new requirements apply to employer plans, what the enhanced NQTL analysis must include, and how to avoid the most common parity violations.
1 lessons · 10 min
Price Transparency: Hospital, Insurer, and PBM Requirements
Understand the full scope of price transparency requirements under the CAA 2026 — hospital price transparency, insurer machine-readable files, PBM drug pricing disclosure, and how employers can use transparency data to drive better plan performance.
1 lessons · 9 min
No Surprises Act: CAA 2026 Updates and Employer Obligations
Understand the No Surprises Act protections, the CAA 2026 updates to the independent dispute resolution process, and the specific obligations employer-sponsored plans must meet to comply with surprise billing protections.
1 lessons · 8 min
Enforcement: DOL, HHS, IRS Penalties and Audit Triggers
Understand the enforcement framework for CAA 2026 — which agencies enforce which provisions, what penalties apply, what triggers a DOL or HHS audit, and how employers can build a defensible compliance posture.
1 lessons · 10 min
Compliance Roadmap: 90-Day, 6-Month, 12-Month Action Plan
A practical, sequenced compliance roadmap for employer plan sponsors — what to do in the first 90 days, what to complete by month 6, and what ongoing compliance looks like at month 12 and beyond.
1 lessons · 11 min
Capstone: Building a CAA 2026-Compliant Benefits Strategy
Synthesize everything from this course into a coherent, actionable benefits strategy — one that meets every CAA 2026 obligation, protects plan participants, manages fiduciary risk, and positions your organization as a leader in employer-led healthcare reform.
1 lessons · 12 min
Earn Your Certificate
Complete all modules, pass the module quizzes, and score 80% or higher on the 25-question final exam to earn your certificate of completion and 9.0 certificate hours.
Educational content only. Employer Benefits IQ content is not legal, tax, accounting, medical, or fiduciary advice. Rules vary by plan design, policy language, employer facts, employee facts, state law, and future regulatory changes. Employers should confirm plan-specific decisions with qualified legal, tax, accounting, carrier, and benefits professionals.