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]
On April 26, 2024, the Office of Civil Rights (OCR) at the U.S. Department of Health & Human Services (“HHS”) issued a Final Rule amending the HIPAA Privacy Rule to protect the ability of individuals to receive reproductive health care when the care is provided lawfully under the circumstances without risk of an individual’s identity [Read More]
In Rev. Proc. 2024-25, the IRS released the inflation-adjusted amounts for 2025 relevant to Health Savings Accounts (HSAs) and high deductible health plans (HDHPs). The table below summarizes those adjustments and other applicable limits. 2025 2024 Change Annual HSA Contribution Limit (employer and employee) Self-only: $4,300 Family: $8,550 Self-only: $4,150 Family: $8,300 Self-only: +$150 [Read More]
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]