Compliance and Legal Department

Reminder: RxDC Reporting Due June 1st

By Stacy Barrow - February 6, 2025

  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]

New ACA-Related Laws Provide More Flexibility to Employers

By Stacy Barrow - December 27, 2024

  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]

Don’t Forget About Your Gag Clause Attestations

By Stacy Barrow - November 20, 2024

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]

IRS Issues Affordability Percentage Adjustment for 2025

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]

REMINDER: PCORI Fees Due By July 31, 2024

  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]