On March 29, 2024, the IRS, DOL and HHS (collectively, “the Agencies”) released final regulations implementing new notice requirements for group hospital or other fixed indemnity plans that begin on or after January 1, 2025. As discussed in more detail below, these final regulations differ from the proposed regulations released by the Agencies on July [Read More]
With the 2023 reference year RxDC reporting deadline approaching soon, plan sponsors should familiarize themselves with recent updates to the RxDC Reporting Instructions. As a reminder, the Consolidated Appropriations Act, 2021 includes a provision that requires group health plans and health insurance issuers (collectively “plans and issuers”) to report certain specified data related to prescription [Read More]
Sponsors of self-funded ERISA plans have fiduciary obligations to plan participants, which includes the obligation to provide a full and fair review of claims and effectively and meaningfully communicate or engage with plan participants regarding claims denials. One district court recently clarified that this obligation may include the need for the plan administrator, which is [Read More]
On July 25, 2023, the agencies released an extensive proposed rule related to the Mental Health Parity and Addiction Equity Act (the “Proposed Rule”) as well as a Technical Release requesting comments on certain proposed data requirements for nonquantitative treatment limitations (“NQTLs”) and the potential for an enforcement safe harbor if certain data requirements are [Read More]
On November 9, 2023, the Internal Revenue Service (IRS) released Revenue Procedure 2023-34, which increases the health flexible spending account (FSA) salary reduction contribution limit to $3,200 for plan years beginning in 2024, an increase of $150 from 2023. Thus, for health FSAs with a carryover feature, the maximum carryover amount is $640 (20% of [Read More]
During our final compliance webinar of our 2024 Educational Webinar Series, Stacy H. Barrow, Esq. provides an overview of significant compliance topics in 2024 and a look at what to expect in 2025. Stacy will review legal and regulatory changes under the ACA and other laws applicable to health and welfare plans and offer thoughts [Read More]
During this informative webinar, Stacy H. Barrow, Esq., BAN’s Director of Compliance, provides an overview of the process when the DOL decides to audit or investigate an employer’s plan for compliance with ERISA and other Federal laws governing group health plans. Attendees will understand what the DOL looks for during an audit, how to best [Read More]
During this webinar, Stacy H. Barrow, BAN’s Director of Compliance, will provide attendees with an update on expanded health plan transparency under the Transparency in Coverage Final Rules and the Consolidated Appropriations Act, 2021, including the No Surprises Act. This session will also include a general update on employee benefits topics. Takeaways include: REGISTER HERE [Read More]
The IRS has released Notice 2023-70, which sets the applicable PCORI fee for plan years ending between October 1, 2023, and September 30, 2024, at $3.22 per covered life. As a reminder, the PCORI was established as part of the Affordable Care Act (ACA) to conduct research to evaluate the effectiveness of medical treatments, procedures, [Read More]
On September 27, 2023, the DOL, IRS, and HHS released FAQs About Affordable Care Act Implementation Part 61 (“FAQ Part 61”) which addresses lingering questions about enforcement of the Transparency in Coverage Final Rules (TiC Final Rules), specifically the provisions of the TiC final rules requiring plans and carriers to post machine-readable files for in-network [Read More]