Legal Alerts

In Rev. Proc. 2025-19, the IRS released the inflation-adjusted amounts for 2026 relevant to Health Savings Accounts (HSAs) and high deductible health plans (HDHPs). The table below summarizes those adjustments and other applicable limits. Out-of-Pocket Limits Applicable to Non-Grandfathered Plans The ACA’s out-of-pocket limits for in-network essential health benefits have also been announced and have [Read More]

  With the 2024 reference year RxDC reporting deadline approaching in June, plan sponsors should re-familiarize themselves with the reporting requirements. The 2024 reference year RxDC Reporting Instructions have been released, though there were no changes to the reporting requirements or data elements from last year. As a reminder, the Consolidated Appropriations Act, 2021 includes [Read More]

  On Monday, December 23, 2024, President Biden signed into law two bills, H.R. 3797 (the “Paperwork Reduction Act”) and H.R. 3801 (the “Employer Reporting Improvement Act”),which will positively impact applicable large employers (“ALEs”) and other entities required to furnish forms 1095-B or 1095-C to individuals. Background Under the Affordable Care Act, ALEs (i.e., employers [Read More]

  The IRS has released Notice 2024-83, which sets the applicable PCORI fee for plan years ending between October 1, 2024 and September 30, 2025 at $3.47 per covered life. The PCORI fee helps fund the Patient-Centered Outcomes Research Trust, which was established as part of the Affordable Care Act (ACA) to conduct research to [Read More]

When the Consolidated Appropriations Act, 2021 (the “CAA”) was enacted on December 27, 2020, it included a provision that prohibits group health plans and health insurance carriers from entering into certain agreements that, either directly or indirectly, restrict the release of certain information related to provider networks and de-identified encounter data, among other things. Such [Read More]

    On September 9, 2024, the DOL, IRS and HHS released a final rule for the Requirements Related to the Mental Health Parity and Addiction Equity Act (The “MHPAEA Final Rule”).  The MHPAEA Final Rule is similar to the Proposed Rule released on July 25, 2023, with some marked differences.  While the MHPAEA Final [Read More]

On October 22, 2024, the Internal Revenue Service (IRS) released Revenue Procedure 2024-40, which increases the health flexible spending account (FSA) salary reduction contribution limit to $3,300 for plan years beginning in 2025, an increase of $100 from 2024.  Thus, for health FSAs with a carryover feature, the maximum carryover amount is $660 (20% of [Read More]

The Internal Revenue Service (IRS) has released Rev. Proc. 2024-35, which contains the inflation adjusted amounts for 2025 used to determine whether employer-sponsored coverage is “affordable” for purposes of the Affordable Care Act’s (ACA) employer shared responsibility provisions and premium tax credit program. As shown in the table below, for plan years beginning in 2025, [Read More]

  Employers that sponsor self-insured group health plans, including health reimbursement arrangements (HRAs) should keep in mind the upcoming July 31, 2024 deadline for paying fees that fund the Patient-Centered Outcomes Research Institute (PCORI) via Form 720, which was recently updated and released by the IRS.  As background, the PCORI was established as part of [Read More]

As a result of the changes to Medicare Part D under §11201 of the Inflation Reduction Act of 2022, on April 1, 2024, CMS released Final Redesign Program Instructions (“Final Program Instructions”) for the Medicare Part D prescription drug program, which are effective starting in 2025. The Final Program Instructions reflect a newly defined standard [Read More]