compliance

compliance

Compliance Recap | February 2024

February saw a potential industry-changing lawsuit against Johnson & Johnson and its plan fiduciaries asserting a breach of fiduciary duties and mismanagement of Johnson & Johnson’s prescription drug benefits program, costing its ERISA plans and employees millions of dollars in the form ...

HHS Releases Updated Drug Data Collection (RxDC) Reporting Instructions

Under Section 204 of the Consolidated Appropriations Act, 2021 (CAA), referred to as “The No Surprises Act” (NSA), all employer-sponsored health plans must satisfy certain transparency requirements by reporting annual prescription drug and health care spending data (often referred to as the ...

Compliance Recap | January 2024

January was a relatively quiet month on the employee benefits compliance front. The Wage and Hour Division of the Department of Labor (DOL) introduced a new rule laying out the guidelines employers can follow to determine how to classify workers. The DOL also released Part 64 of its FAQs about ...

Compliance Alert | ACA Reporting Updates, Obligations & Deadlines

Do you have a plan for meeting your ACA Reporting obligation?  At a time when IRS ACA penalties are increasing, paper filing is disappearing and submissions are getting more complex, the urgency for timely and compliant filing is more important than ever. ACA Reporting Updates Please review the ...

Compliance Recap | December 2023

December provided employers an opportunity to review year-end compliance to prepare for the new year. Employers confirmed that their worksite posters are appropriate for the type of business, number of employees, and state, and are the most recent version. Employers who are applicable large ...

Compliance Recap | November 2023

November brought an ACA FAQ from the Departments of Labor, Health and Human Services, and the Treasury ensuring that SBCs and claims and appeals notices are available when more than 10 percent of the population is literate only in a specific non-English language. UnitedHealth’s pharmacy benefit ...

Gag Clause Prohibition Compliance Attestation

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 ...

IRS Releases 2024 Benefit Plan Limits

The IRS recently released the 2024 benefit plan limits based on the annual cost-of-living adjustments in the Internal Revenue Code. These limits take effect beginning January 1, 2024. Final limits for health FSAs and DCAPs are still pending. Employers should update their Summary Plan ...

Compliance Recap | October 2023

October saw the release of adjusted civil penalties for HIPAA violations, ACA requirements, and Medicare Secondary Payer rules. Health plan limits and maximums for 2024 including high deductible health plans (HDHPs), health savings accounts (HSAs) flexible spending accounts (FSAs), and ...

FAQs on Implementation of Transparency in Coverage Regulations (ACA Part 61)

The Department of Labor (DOL), the Internal Revenue Service (IRS), and the Department of Health and Human Services (HHS) (collectively, the “Departments”) recently issued FAQ guidance on Part 61 of the Affordable Care Act (ACA), addressing the implementation of the transparency in coverage ...

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