compliance

compliance

Compliance Alert | Gag Clause Prohibition Compliance Attestation (GCPCA)

Title II (Transparency) of Division BB of the Consolidated Appropriations Act (“CAA”) prohibits group health plans from entering into an agreement with a health care provider, network or association of providers, third-party administrator (TPA), or other service provider that include language ...

Compliance Recap | October 2024

October brought the second of two Centers for Medicare & Medicaid (CMS) Medicare Part D annual disclosures, in the form of Creditable Coverage Letters. The IRS released the 2025 cost-of-living adjustment information affecting employee benefit plans. We were reminded that while there are no ...

IRS Releases 2025 Benefit Plan Limits

As we approach 2025, it’s essential for employers to stay informed about the updated cost-of-living adjustments (COLAs) that impact employee benefits. Recent IRS updates affect key programs such as flexible spending accounts (FSAs), Qualified Small Employer Health Reimbursement Arrangements ...

Brinson Compliance Annual Notices

Employers that sponsor group health plans should provide certain benefit notices in connection with their plans’ open enrollment periods.  Although these annual notices may be provided at different times throughout the year, employers often choose to include them in the new hire packet, at open ...

Compliance Recap | September 2024

September brought the due date for the Summary Annual Report, which summarizes the Form 5500 contents. Employers prepared to send out the required Medicare Part D Creditable Coverage letters to eligible participants and enrolled beneficiaries. The Departments released final rules on the MHPAEA ...

IRS Releases 2025 ACA Affordability Percentage for Employer-Sponsored Health Coverage

The IRS recently released its annual inflation adjustment to the percentage of household income used to determine whether an employer’s offer of health care coverage under the Affordable Care Act (ACA) is affordable. The good news for employers is that the percentage has significantly increased ...

DOL Confirms Cybersecurity Guidelines Apply to Health and Welfare Plans under ERISA

The Department of Labor’s Employee Benefits Security Administration (EBSA) has confirmed in Compliance Assistance Release No. 2024-01 that its cybersecurity guidance issued in April 2021 generally applies to all employee benefit plans, including health and welfare plans. In the prior guidance, ...

Final Rules under the Mental Health Parity and Addiction Equity Act

On Sept. 9, 2024, the U.S. Departments of Health and Human Services (HHS), Labor (DOL), and the Treasury (IRS) (collectively, the Departments) released new final rules implementing the Mental Health Parity and Addiction Equity Act (MHPAEA). The final rule updates the way the Departments ...

Compliance Recap | August 2024

In August, the ban on non-compete agreements was struck down by a court stating that the FTC did not have the power to implement the ban and that its application was too broad. The FDA approved new and updated COVID-19 vaccines for adults and children as part of the preventive care mandate for ...

Compliance Recap | July 2024

July was a busy month for sponsors of group health plans. The final DOL rule on overtime exemption requirements went into effect July 1. IRS Form 5500, due on July 31 for calendar year plans, applies to most public and private sector businesses providing plans to 100 or more participants. Also ...

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