compliance
November 6, 2023
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 ...
October 17, 2023
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 ...
October 13, 2023
Proposed Guidance for Mental Health Parity Regulations
On July 25, 2023, the Departments of Treasury, Labor, and Health and Human Services (the “Departments”) released proposed rules on the Mental Health Parity and Addiction Equity Act of 2008 (MHPAEA) and published in the Federal Register on August 3, 2023. These proposed regulations would update ...
October 12, 2023
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 ...
October 4, 2023
Compliance Recap | September 2023
In September, plan sponsors began sending out Medicare Part D Creditable Coverage notices, and both Oregon and Maine announced Paid Family and Medical Leave laws. Sponsors of group health plans began completing the required Gag Clause Attestation due by the end of 2023. The Departments of ...
September 6, 2023
Compliance Recap | August 2023
In August, the IRS announced a decrease in the ACA affordability percentage to 8.39%. Both Colorado and Illinois expanded their leave laws. The Department of Labor released its updated version of the Premium Assistance Under Medicaid and the Children’s Health Insurance Program (CHIP) Notice. ...
September 5, 2023
IRS Significantly Decreases 2024 ACA Affordability to 8.39%
The Internal Revenue Service (IRS) recently released Revenue Procedure 2023-29, reducing the Affordable Care Act’s (ACA) affordability percentage to 8.39% for plan years beginning in 2024, down from 9.12% in 2023 (which was further decreased from 9.61% in 2022). The affordability percentage is ...
August 7, 2023
Compliance Recap | July 2023
July saw two proposed rules, one focusing on short-term, limited-duration health plans, and one addressing provider networks and data collection for the Mental Health Parity and Addiction Equity Act (MHPAEA). The PCORI fee was due on July 31 for plan sponsors of self-insured groups and HRAs. ...
July 31, 2023
Employers Encouraged to Expand Access to Group Health Plans
In a letter dated July 20, 2023, from the Center for Medicare and Medicaid Services (CMS) to employers, plan sponsors and issuers, the Biden-Harris Administration (the Administration) is encouraging those entities to expand mid-year enrollment opportunities in group health plans for employees ...
July 28, 2023
New FAQ Guidance on No Surprises Act and Transparency in Coverage
Recently, the Departments of Labor, Treasury, and Health and Human Services (the “Departments”) released new frequently asked questions (FAQs) on the No Surprises Act and the Transparency in Coverage final rules, giving employers more guidance and clarity around health plan out-of-network ...
