The navigation requirement took effect months ago. Most plans haven't checked whether they're actually meeting it.
HRSA's updated Women's Preventive Services Guidelines require non-grandfathered group health plans to cover individualized patient navigation for breast and cervical cancer screening — no cost-sharing — for plan years beginning on or after December 30, 2025 (January 1, 2026 for calendar-year plans). For most plans, that means it applies right now.
This guide gives plan sponsors and consultants a practical gap checklist: what the guidelines actually describe, and the twelve questions that surface the gap between what's attested and what's delivered.
Get the compliance gap checklist
PDF — the requirement in plain English, a 12-point delivery audit, and SPD/SMM language considerations to raise with counsel.
What the guidelines actually say.
On December 20, 2024, HRSA approved updates to the Women's Preventive Services Guidelines (published in the Federal Register, 89 FR 106522, December 30, 2024). Under the ACA's preventive services provisions, non-grandfathered group health plans and issuers must cover the updated services without cost-sharing for plan years beginning on or after December 30, 2025 — January 1, 2026 for calendar-year plans.
Two additions matter for cancer strategy:
- Complete screening coverage: additional breast imaging (e.g., ultrasound, MRI) and pathology services needed to complete the screening process, without cost-sharing.
- Patient navigation: "individualized person-to-person patient navigation" for breast and cervical cancer screening and follow-up — in-person, virtual, or hybrid — including person-centered assessment and planning, help accessing and navigating the healthcare system, referrals, and patient education.
And it keeps moving: in December 2025, HRSA approved a further update to the cervical cancer screening guideline, effective with plan years starting in 2027. Preventive-services compliance is becoming an annual exercise, not a one-time SPD edit.
Why "our carrier handles it" deserves a second look.
Most plan sponsors addressed the 2026 changes the way their advisors suggested: confirm with the carrier or TPA, update the SPD or issue an SMM. That handles the coverage question. It often leaves the delivery question open:
- Is anyone proactively offering navigation to members due or overdue for breast and cervical screening — or does it only exist for members who find a phone number?
- Does the navigation include person-centered assessment and an individualized plan, as the guidelines describe — or is it general case management relabeled?
- Does it persist through follow-up — the additional imaging and pathology the same update made cost-free — or end at the first booked appointment?
- Could the plan document who received navigation, when, and what it consisted of, if asked?
These are the questions a good consultant asks in a stewardship meeting — and the ones the gap checklist walks through in detail.
We deliver the navigation, and document every instance.
Stage Zero delivers individualized, person-to-person screening navigation — proactive outreach based on risk and screening status, person-centered plans, scheduling and follow-up support, and audit-ready documentation of every navigation delivered. That's the difference between a checkbox in the plan document and a member who actually gets the call.
This page summarizes publicly available regulatory guidance for general informational purposes only and does not constitute legal advice. Requirements may be affected by ongoing litigation concerning ACA preventive-services mandates and by future guideline updates — though the case for completed screenings stands on its own economics regardless of how the mandate evolves. Plan sponsors should consult their own legal counsel and benefits advisors regarding their specific compliance obligations. Sources: HRSA Women's Preventive Services Guidelines; Federal Register 89 FR 106522 (Dec. 30, 2024) and subsequent 2026 updates.