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.

The Transparency in Coverage Final Rule (TiC) requires non-grandfathered group health plans and carriers to make personalized out-of-pocket cost information available to participants through an internet-based self-service tool. The purpose of the self-service tool is to provide participants with real-time, accurate estimates of...

The deadline for the first CAA gag clause attestation is fast approaching! Employers should act now to ensure their group health plan contracts are compliant and attestations are timely submitted.

Employers must notify individuals who are eligible to participate in their medical plan whether the plan's prescription drug coverage is "creditable" or "non-creditable" as compared to Medicare Part D coverage.

Based on DOL FAQ guidance and subsequent commentary, the COVID-19 National Emergency Outbreak Period ended on July 10, 2023. This means that the tolling of certain ERISA plan deadlines (e.g., COBRA elections, payments and certain notices, HIPAA special enrollments, and claims and appeals filings) will no longer be required.

Now that the COVID-19 National Emergency has ended, employers must prepare for the end of the Outbreak Period. Based on DOL FAQ guidance and subsequent commentary, the Outbreak Period will end on July 10, 2023. This means that the tolling of certain ERISA plan deadlines (e.g., COBRA elections, payments and certain notices, HIPAA special enrollments, and claims and appeals filings) will no longer be required.

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

Under the CAA, Section 204, insured and self-insured group health plans are required to report significant information regarding prescription drug and healthcare spending to the government. The 2020 and 2021 calendar year data submissions are due by December 27, 2022. However, under recently announced relief, a submission grace period is available to employers who make a good faith submission of the 2020 and 2021 data on or before January 31, 2023.