Expanded Preventative Services for Plan Year 2026: Breast Cancer Screening

On 12/30/24, the Health Resources and Services Administration (HRSA) issued a notice  including an important revision focused on “Breast Cancer Screening for Women at Average Risk.” Under the new guidelines, applicable insurance plans will be required to ensure coverage for enhanced breast cancer screening measures, including additional imaging services, at no cost to participants.  While there are other updates to the preventative services list, the expanded breast cancer screening methods will likely have financial impacts to 2026 plan years. 

Notice 2024-75 issued by the IRS clarified that HSA-qualifying High-Deductible Health Plans (HDHPs) have the option to include pre-deductible coverage for a broader range of breast cancer screening methods, extending beyond traditional mammograms.  

These changes are designed to improve early detection and streamline access to preventive care. For employers, this means preparing for compliance adjustments well in advance while evaluating the potential cost impacts of these expanded requirements. It is crucial for organizations to stay informed and align their health plans accordingly to meet these forthcoming standards. 

WHAT’S CHANGING IN 2026? 

In December 2024, HRSA approved updates to the Guidelines.  It listed an additional two preventive services: Screening and Counseling for Intimate Partner and Domestic Violence and Breast Cancer Screening for Women at Average Risk. HRSA also approved a new guideline for Patient Navigation Services for Breast and Cervical Cancer Screening. Here’s the short version:    

• Expanded Breast Cancer Screening Requirements
  Previously, group health plans only had to cover mammograms. But starting with plan years on or after January 1, 2026, the Affordable Care Act (ACA) requires plans to cover additional imaging and pathology required to complete the screening process at no cost to participants. Think MRIs, ultrasounds, and pathology evaluation for follow-ups.  

• New Navigation Services for Breast and Cervical Cancer
  Health plans will need to offer patient navigation services that ensure members have access to support like scheduling, education, social services, language translation, and more. These services can be virtual, in person, or hybrid.

Why it Matters? 

This isn’t just another compliance box to check. It’s about improving employee well-being while balancing potential financial and operational impacts. Here’s what you should know: 

• Cost Implications:
  Expect some initial cost increases from claims for added services, along with possible premium hikes.  

• Claims Challenges:
  Changes may create confusion around coding or administrative processes, so early fixes and are key.  

How to Stay Prepared

Compliance doesn’t have to be stressful. Here’s your action plan for the updated breast cancer screening requirements: 

1. Review Current Coverage 
   Check your current plan against the new requirements. Are expanded services and no-cost-sharing already included? 
2. Update Claims Processes 
   Collaborate with carriers and third-party administrators to ensure your systems align with the 2026 no-cost mandates. 
3. Adjust Budgets 
   Use historical claims data to estimate cost impacts and prepare for possible premium changes. 
4. Communicate with Employees 
   Make sure your workforce knows about these enhancements through clear and engaging updates. 
5. Monitor and Adjust 
   After implementation, track usage and costs to fine-tune processes and highlight the value of these changes. 

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