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.

This legislation makes certain modifications to the ACA’s employer mandate reporting requirements that aim to simplify Forms 1095-B and 1095-C reporting for employers and health insurance providers

the CAA prohibits group health plans and insurers from directly or indirectly entering contracts offering access to provider networks that contain certain types of “gag clauses.” The CAA requires plans and insurers to annually attest to compliance with its gag clause prohibition for contracts entered since the first attestation made in 2023.

On October 22, 2024, the IRS issued Revenue Procedure 2024-40, providing certain cost-of-living adjustments for a wide variety of tax-related items, including health FSA contribution limits, transportation and parking benefits, qualified small employer health reimbursement arrangements (QSEHRAs), the small business tax credit, and other adjustments for tax year 2025. Those changes are outlined below.

The deadline for 2024 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 imposed the PCOR fee on health plans to support clinical effectiveness research. The PCOR fee, which applies to plan years ending on or after October 1, 2012, and before October 1, 2029, is generally due by July 31 of the calendar year following the close of the plan year. PCOR fees must be...

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 2023 calendar year (termed the “reference year”) is due by June 1, 2024.

Individuals who were HSA-eligible in 2023 have until the tax filing deadline, April 15, 2024, to make or receive 2023 HSA contributions. The 2023 HSA contribution limit is $3,850 for self-only HDHP coverage and $7,750 for any tier of HDHP coverage other than self-only. Employer HSA contributions, if any, are included in the applicable limit.

Applicable large employers (ALEs) with 50 or more full-time employees (FTEs), including full-time equivalent employees, in the prior year who sponsored group health plans (whether insured or self-insured) must comply with IRC Section 6056 reporting in early 2024. Specifically, ALEs must complete and distribute Form 1095-C to full-time employees by March 1, 2024.

All 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. Generally, “creditable coverage” refers to prescription drug coverage that is expected to pay (based on the actuarial value) on average at least as much as Medicare Part D coverage.