Washington, D.C. – Leading stakeholders representing employers, businesses, and environmental organizations urged the Department of Labor (DOL) to finalize its proposal to permit default electronic delivery (e-delivery) for group health plan communications under the Employee Retirement Income Security Act of 1974 (ERISA). The groups also encouraged DOL to extend the default e-delivery approach to all ERISA-covered welfare plans in its final rule.
“The administration’s proposal takes the important step of modernizing outdated regulations to improve the employee experience in interacting with and managing their benefits, while delivering meaningful cost savings to employers,” said James Gelfand, President and CEO of The ERISA Industry Committee. “We appreciate our partnership with aligned stakeholders in support of this proposed change, and we urge DOL to not only finalize it, but also to extend it to all ERISA-covered welfare plans.”
The following organizations signed a comment letter submitted to DOL supporting the policy:
- The ERISA Industry Committee
- AHIP
- American Council of Life Insurers (ACLI)
- Associated General Contractors of America
- Association for Behavioral Health and Wellness (ABHW)
- Blue Cross Blue Shield Association
- Business Group on Health
- CHRO Association
- Delta Dental Plans Association
- Environmental Paper Network
- Fidelity Investments
- Healthcare Leadership Council
- Marsh
- MetLife
- NABIP
- National Alliance of Healthcare Purchaser Coalitions
- National Association of Dental Plans (NADP)
- National Association of Professional Employer Organizations
- National Coordinating Committee for Multiemployer Plans (NCCMP)
- National Retail Federation
- Partnership for Employer Sponsored Coverage (P4ESC)
- Purchaser Business Group on Health
- Self Insurance Institute of America
- SAG-AFTRA
- Silicon Valley Employers Forum
- Small Business Majority
- UnitedHealth Group
- U.S. Chamber of Commerce
E-delivery represents a commonsense policy for workers and employers alike, and one that has been permitted for communications regarding retirement benefits for years. The proposed rule is a very welcome next step extending the policy to health benefit communications. ERIC-commissioned polling conducted by Ipsos in 2025 found that 95% of employees enrolled in ERISA-covered health benefit plans are comfortable accessing benefits information electronically, and 91% already do so. Four in five say e-delivery provides real-time access to information and helps them make more informed health care decisions, while nearly eight in 10 prefer it as the default.
As part of DOL’s assessment of the e-delivery proposal, the agency estimates that an e-delivery safe harbor for health plans would result in up to $395 million in net annual savings, largely accruing to American workers and businesses. The Department also estimates that the proposed rule could eliminate the unnecessary printing and mailing of up to 11 billion sheets of paper each year.
“This reform, once finalized, will save millions in administrative expenses that can be reinvested into employer health plan programs and benefits. It will also improve access to and utility of the disclosures, potentially enabling employees and their families to take action directly from the electronic communication itself,” said Garrett Hohimer, Vice President of Policy and Advocacy, Business Group on Health.
Extending the final rule to all ERISA-covered welfare plans would meaningfully expand these savings while creating a more consistent experience for employees across their benefits. A 2025 analysis by Avalere Health of all ERISA health and welfare plan disclosures estimated that default e-delivery could save up to $19.5 billion over 10 years and significantly reduce the 20.4 billion sheets of paper currently printed and mailed each year across these plans.
“By making electronic delivery the default, the Department has a historic opportunity to reduce unnecessary paper use without compromising consumer choice,” said Elizabeth Underwood, Ph.D., Director, Environmental Paper Network. “Extending this flexibility to all ERISA-covered welfare plans would multiply those benefits, conserving natural resources while reducing waste and emissions.”
Read the full letter here.