2026 Employee Benefits Market Outlook 18 Looking ahead, the agencies stated that they intend to propose rulemaking to provide additional ways for cer- tain fertility benefits to be offered as a limited excepted benefit. They are also considering changes to the stan- dards for supplemental health insurance coverage, including a supplemental benefit for fertility coverage, so that these arrangements can more easily meet the conditions for excepted benefit status. At the same time, state-level mandates continue to expand. California recently joined more than 20 other states with fertility benefit mandates. Under the California law, large group health plans (generally those that cover over 100 people) must cover fertility services, including IVF. Although originally scheduled to take effect on July 1, 2025, implementation was delayed and will now apply to plans issued, amended or renewed on or after Jan. 1, 2026. While small group plans will not be required to cover such services, they are required to offer such coverage beginning Jan. 1, 2026. As fertility benefits gain traction through both federal initiatives and expanding state mandates, employers have an opportunity to lead in offering inclusive, fam- ily-friendly benefits. Cost sharing and coverage gaps, particularly for self-funded plans not subject to state mandates, remain a barrier to access. A single IVF cycle can exceed $30,000, with typical costs ranging from $12,000 to $25,000 per cycleand multiple cycles are often required to achieve pregnancy, cre- ating a substantial financial strain. In 2026, employers should assess whether their current health plans meet applicable state mandates, particularly in states like California, where new requirements will soon take effect. Employers with self-funded plans that are not subject to state mandates should consider voluntary coverage or supplemental benefits to remain com- petitive. Monitoring forthcoming federal rulemaking on excepted benefits and supplemental coverage can help identify cost-effective strategies for offering fer- tility benefits outside traditional group health plans. Additionally, budgeting for high-cost treatments (such as IVF) and exploring reimbursement arrangements or partnerships with fertility care platforms can help mit- igate employee out-of-pocket expenses. Overall, clear communication about available benefits and support services reinforces an employer s commitment to fam- ily-building and employee well-being, strengthening attraction, retention and productivity.