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U.S. Budget Bill and uncertainty — What are the implications on 2025 plans and beyond?

By Michelle Acciavatti , Lori Wisper , Nicole Bitter, JD , Beth Ashmore and Matt Kamensky | September 3, 2025

Dive into the key provisions of the U.S. Budget Bill, the implications on employers and the steps organizations can take to navigate these changes.
Benefits Administration and Outsourcing Solutions|Compensation Strategy & Design|Employee Experience|Executive Compensation|Health and Benefits|Retirement|Total Rewards
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2025 has provided no shortage of challenges and obstacles for organizations and their HR programs. The 2025 U.S. Budget Bill introduces several significant changes that will impact employee benefits, compensation and retirement programs. These changes not only affect how employers manage their workforces but also require strategic planning to ensure compliance and a competitive edge in the market. 

Key provisions and their implications

Ensuring compliance with the Fair Labor Standards Act (FLSA)

One of the most notable changes in the U.S. Budget Bill is the introduction of nontaxable overtime income. Employees can now take a tax deduction on their overtime earnings, up to $12,500 for single filers and $25,000 for married filers. This means more money in employees' pockets, a change that is naturally welcomed by the workforce. However, as employers, it's crucial to consider the potential implications of this provision. For one, it may make overtime even more attractive to non-exempt employees, leading to an increased demand for overtime hours.

A second concern is that employees may work overtime without permission, and according to the FLSA, employers have to pay regardless of whether it was approved or not. This could result in higher labor costs, which might not have been part of your initial budgeting plans.

Employers should:

  • Review overtime policies: Assess current overtime practices to ensure they are clear about approval processes and the consequences for not following them.
  • Communicate overtime policies: Remind employees of the overtime policies, including the approval process.
  • Update exemption status: Reevaluate the exemption status of job roles to avoid misclassification and ensure compliance with FLSA regulations.
  • Strategic workforce planning: Consider the potential increase in labor costs due to higher demand for overtime hours and adjust workforce planning accordingly.

Enhanced High-Deductible Health Plans (HDHPs) and Health Savings Accounts (HSAS)

The healthcare landscape is also undergoing significant changes. The Bill enhances flexibility for HDHPs and HSAs by allowing telehealth and direct primary care services without violating the first-dollar coverage rule. This change is retroactive to the start of 2025, providing more flexibility and access to healthcare services for employees.

Employers should:

  • Evaluate your current health plan offerings: Conduct health plan design projects to evaluate the cost implications of the new flexibility for HDHPs and HSAs. Consider adding or enhancing telehealth and direct primary care services.

Sunsetting of premium tax credits and Medicaid cuts

The sunsetting of premium tax credits at the end of 2025 and significant cuts to Medicaid may drive more individuals to seek employer-sponsored plans. It is expected that upwards of 8 million individuals over the next 10 years may lose access to Medicaid. These changes may drive more individuals to seek employer-sponsored health plans, potentially increasing healthcare costs and enrollment.

Employers should:

  • Prepare for potential increases in health plan enrollments.
  • Conduct an affordability analysis to ensure your plans remain competitive.
  • Communicate the value of your health plans to employees.

Increase in Dependent Care Flexible Spending Accounts (DCFSAs) limit

The limit for Dependent Care Flexible Spending Accounts (DCFSAs) has been raised from $5,000 to $7,500. This change allows employees to set aside more pre-tax dollars for dependent care expenses, potentially reducing their taxable income and increasing their take-home pay. However, employers must consider the impact on non-discrimination testing rules before raising the limit. Many employers have to limit the amount highly-compensated employees can set aside in Dependent Care Accounts because they don’t have enough participation from their non-highly-compensated employees. This could result in frustration if limits are increased and then have to be adjusted to pass testing.    

Employers should:

  • Review and adjust your DCFSA policies.
  • Educate employees on the new limit and its benefits.
  • Consider doing preliminary testing to ensure highly-compensated employees can take advantage of the increased limits.
  • Ensure ongoing compliance with non-discrimination testing.

New tax exemptions for paid family and medical leave

The tax exemptions for paid family and medical leave will provide additional financial support to employees during leave periods.

Employers should:

  • Assess your current paid family and medical leave policies.
  • Consider implementing or enhancing these policies.
  • Communicate the new tax exemptions to employees.

Introduction of Trump Accounts

New IRA-type accounts, known as Trump Accounts, have been introduced for individuals under 18 and newborns.  Related to the newborn accounts, they provide a $1,000 contribution for newborns born between 2025 and 2028.

While this provision primarily benefits employees, employers can:

  • Educate employees about Trump Accounts.
  • Consider offering matching contributions.
  • Integrate information about these accounts into your benefits communication.

Retirement wellbeing and risk

While the Budget Bill didn’t have significant retirement implications – previous legislation and market trends such as SECURE 2.0 and interest rate volatility are causing us to review our retirement programs.

Taking these into consideration, employers should:

  • Continue implementation of SECURE 2.0 changes, including the January 1, 2026 effective date of Roth catch up contributions: Employers need to ensure all systems are updated and compliant by working with your payroll and recordkeepers to implement the new rules, and addressing employee communications.
  • Scenario modeling on pension plan contributions and costs: Analyze the effects of changes in interest rates and potential pension costs or cash contributions. Use scenario modeling to identify the best strategies to mitigate financial risks. Consider the effects any workforce changes may have.
  • Surplus asset management: Explore opportunities to deploy surplus assets to address benefit program costs, enhancing the flexibility and sustainability of benefit programs.

Keeping employees engaged

While the U.S. Budget Bill has some favorable aspects to employees, it adds to the many changes in the market today and can increase the feeling of uncertainty. Employers can use this opportunity to manage these anxieties and maintain productivity and high performance, thereby differentiating their value proposition from competitors. A critical step in this process is understanding what programs employees value and the trade-offs they might be willing to consider.

Employers should:

  • Conduct employee surveys: Gather insights on what benefits and compensation practices employees value most. This can help in identifying areas for improvement and aligning programs with employee needs.
  • Communicate changes clearly: Use clear and transparent communication to manage employee uncertainty and maintain productivity. Personalized total reward statement videos and bite-sized micro-learning can be effective tools.
  • Align with business strategy: Ensure that benefit programs are consistent with the overall business strategy and create a framework for future communications that resonates with employees.

Breakthrough the uncertainty

The 2025 U.S. Budget Bill introduces a range of changes that can both benefit and challenge employers. By breaking through the uncertainty and proactively addressing these provisions, businesses can ensure they remain competitive, compliant and supportive of their workforce. The key is to stay informed, communicate effectively and adapt your benefits and compensation strategies to meet the new landscape. 

What you can do now:

  1. Ensure compliance with FLSA: Review and update overtime policies and exemption status to manage potential increased labor costs.
  2. Conduct affordability analysis: Evaluate the cost implications of new health plan and retirement program provisions to ensure sustainability and competitiveness.
  3. Scenario modeling and budgets: Prepare for potential changes in health plan enrollments and retiree medical programs by conducting scenario modeling and adjusting budgets accordingly.
  4. Understand what employees value: Gather employee perceptions and benchmark your total rewards programs to ensure they align with employee needs and expectations.

By taking these proactive steps, you can navigate the changes introduced by the 2025 U.S. Budget Bill and create a benefits and compensation strategy that supports your employees and drives your organization forward.

Authors


North America Health, Wealth & Career Leader
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Managing Director, Work & Rewards
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Managing Director, Retirement

National Practice Leader,
Compliance, Audit and MHPAEA
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North America Leader – Employee Experience
WTW
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