Legal Alerts

IRS Releases 2024 HSA Contribution Limits and HDHP Deductible and Out-of-Pocket Limits

By Stacy Barrow - May 26, 2023

In Rev. Proc. 2023-23, the IRS released the inflation-adjusted amounts for 2024 relevant to Health Savings Accounts (HSAs) and high deductible health plans (HDHPs). The table below summarizes those adjustments and other applicable limits.   2024 2023 Change Annual HSA Contribution Limit (employer and employee) Self-only: $4,150 Family: $8,300 Self-only: $3,850 Family: $7,750 Self-only: +$300 [Read More]

Agencies Informally Indicate that the Outbreak Period Tied to the COVID-19 National Emergency Ends July 10, 2023

By Stacy Barrow - April 17, 2023

On April 10, 2023, the President signed H.J.Res. 7, which ended the COVID-19 national emergency on April 10, 2023, approximately one month earlier than anticipated.  However, prior to the passage of H.J. Res. 7, the DOL and other federal agencies issued guidance in the form of FAQs that indicate an end date of May 11, [Read More]

Agencies Issue Guidance on the End of the COVID-19 Emergencies (Revised based on the President’s Signature of H.J.Res. 7 on April 10, 2023)

By Stacy Barrow - April 10, 2023

On January 30, 2023, President Biden issued a Statement of Administration Policy announcing his intent to end the COVID-19 national and public health emergencies on May 11, 2023.  However, on April 10, 2023, the President signed H.J.Res. 7, which ends the COVID-19 national emergency approximately one month earlier than anticipated, on April 10, 2023.  On [Read More]

Agencies Release Revised Instructions for 2022 Reference Year RxDC Reporting

On March 3, 2023, federal agencies released revised Prescription Drug Data Collection (RxDC) Reporting Instructions applicable to the 2022 reference year.  RxDC reporting for the 2022 reference year is due on or before June 1, 2023.    Background The Consolidated Appropriations Act, 2021 (“CAA, 2021”) includes a provision that requires group health plans and health [Read More]

CAA, 2023 Eliminates MHPAEA Exemption for Self-Funded Non-Federal Governmental Health Plans

CAA, 2023 Eliminates MHPAEA Exemption for Self-Funded Non-Federal Governmental Health Plans On December 29, 2022, the President signed the Consolidated Appropriations Act, 2023  (“CAA, 2023”), into law.  The CAA 2023, which is largely a bipartisan spending bill, sunsets provisions of the Public Health Service Act which permitted large, self-funded, non-federal governmental plans (i.e., self-funded state [Read More]

Agencies Extend RxDC Reporting Deadline to January 31, 2023

On December 23, 2022, federal agencies released ACA and CAA Implementation FAQ Part 56 which extends the December 27, 2022 deadline for Prescription Drug Data Collection Reporting (“RxDC Reporting”) through January 31, 2023, and provides relief for plans that use a good faith, reasonable interpretation of the regulations and RxDC Reporting Instructions when submitting their [Read More]