Sarah Borders March 11, 2026 2 min read

Federal Enforcement Priorities for 2026

Employee Benefits Security Administration (EBSA) has identified key focus areas for enforcement under ERISA:

  • Cybersecurity: Increased emphasis on system hardening and secure data handling.
  • Mental Health & Substance Use Disorder Parity: Ongoing investigations around:
    • Access to in-network MH/SUD providers
    • Medical necessity criteria
    • Barriers to autism therapy, eating disorder treatments, and Medication Assisted Treatment for opioid use disorders
  • Surprise Billing
    1. A high number of Independent Dispute Resolution cases were decided in favor of providers.
    2. Plans need to ensure correct processes/documentation.
  • Abusive MEWAs: Continued monitoring of noncompliant association health plans, which can pose fraud or insolvency risks.

Bottom line:
Employers should review compliance processes proactively. Issues in these areas can lead to audits, penalties, or investigations.

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Sarah Borders

Principal, Benefits Compliance Solutions. Sarah has spent the last 15 years in the employee benefits industry, has numerous designations and serves on NAHU’s Employer Working Group Subcommittee and is an active board member of Austin AHU. She recently stepped down as Vice President of Benefits Compliance at one of the nation's largest brokerage firms to start her own compliance consulting practice. Her designations include an active license with the Texas Department of Insurance, CEBS (Certified Employee Benefits Specialist), Certified Health Care Reform Professional, HIPAA certification and Health Care Service Associate. She holds an MBA from Texas A&M Corpus Christi and a BA from University of Incarnate Word. Her consulting firm, Benefits Compliance Solutions, partners with employers to identify unknown risks and avoid hundreds of thousands of dollars in fines and lawsuits from failure to comply with their healthplan obligations.

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