The deadline for 2025 CAA gag clause attestations is just around the corner. Employers should act now to ensure their group health plan contracts are compliant and attestations are timely submitted.

The ACA requires insurers to submit an annual report to HHS to account for plan costs. If the insurer does not meet the medical loss ratio (MLR) standards, this means that too large a portion of the premiums charged in the previous year went toward the insurer’s administration, marketing, and profit instead of going toward paying claims and quality improvement initiatives.

Employers of all sizes that sponsor prescription drug plans (whether fully insured or self-insured) are required to annually inform Medicare eligible individuals whether the plan’s coverage is “creditable” or “non-creditable.”

The CAA, 2021 requires fully insured and self-insured group health plans to annually report certain information regarding prescription drug and healthcare spending to CMS. Reporting for the 2024 calendar year (termed the “reference year”) is due by June 1, 2025.

Individuals who were HSA-eligible in 2024 have until the tax filing deadline, April 15, 2025, to make or receive 2024 HSA contributions. The 2024 HSA contribution limit is $4,150 for self-only HDHP coverage and $8,300 for any tier of HDHP coverage other than self-only. Employer HSA contributions, if any, are included in the applicable limit. Those aged 55 and older are permitted an additional catch-up contribution of $1,000. As indicated below,

Under prior guidance, the Forms 1095-C must be delivered to full-time employees by March 3, 2025, by mail, hand delivery, or electronic delivery (the latter only if proper consent in accordance with IRS instructions). However, under the Paperwork Burden Reduction Act (PBRA), which was recently enacted, employers have the option to provide Form 1095-C to such employees only upon request.

Fully insured and self-insured plans (including level-funded plans) of all sizes, including church and governmental plans, must annually disclose to CMS whether their plan’s prescription drug coverage is creditable.

Large employers that sponsor fully insured or self-insured (including level funded) group health plans are required to report information to the IRS annually via Form W-2 regarding the cost of health coverage provided to employees during the prior calendar year.

The ACA requires large employers that sponsor fully insured or self-insured (including level funded) group health plans to report information to the IRS annually via Form W-2 regarding the cost of health coverage provided to employees during the prior calendar year. If PPI billed your medical plan during the reporting year, the Cost of Coverage report, found in your PPI Connect Portal, can be very helpful for completing this requirement.