In May, applicable large employers were focused on RxDC reporting, due in June, and the PCORI filing, due in July. The U.S. Departments of Labor, Health and Human Services, and the Treasury jointly announced a pause in enforcement of the 2024 Final Rule implementing the Mental Health Parity and Addiction Equity Act (MHPAEA), and a […]
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FAQs about the Patient Centered Outcomes Research Institute (PCORI) Fee
The Patient-Centered Outcomes Research Institute (PCORI) fee initially applied from 2012 to 2019. However, in December 2019, the Further Consolidated Appropriations Act, 2020 extended the fee to 2029. The PCORI fee applies to all plans that provide medical coverage to employees. Medical coverage includes preferred provider (PPO) plans, health maintenance organization (HMO) plans, point-of-service (POS) […]
Read moreCOBRA Compliance: Why “Good Faith” Isn’t Good Enough
READ TIME: 4 MINUTES Recent litigation emphasizes a vital reminder for employers that with COBRA notices, a good faith effort to comply is not a legal defense. The case Marrow v. Carpenter Company centers on an employee who claimed she lost coverage due to a deficient COBRA notice. The court ruled that a “good faith […]
Read moreWhen is a Plan an ERISA Plan?
READ TIME: 5 MINUTES Key Takeaways from Hansen v. Laboratory Corporation of America A short-term disability (STD) plan is not automatically covered under ERISA just because it’s included in an employer’s benefits package. Even if an employer treats the plan like an ERISA plan – such as including it in a wrap plan or on […]
Read moreCMS Updates Simplified Method for Determining Creditable Coverage Status for 2026
READ TIME: 6 MINUTES This month, the Centers for Medicare and Medicaid Services (CMS) announced final instructions for the changes to Medicare Part D prescription drug coverage mandated by the Inflation Reduction Act of 2022 (IRA) which will affect employer-sponsored plans in 2026. The changes are intended to enhance benefits and offer cost savings […]
Read moreImpact of Executive Order on Sex and Gender Identity
On January 20, 2025, the Trump administration issued an executive order redefining the terms sex, gender identity, and related concepts as they pertain to federal law and policy. These changes will affect compliance requirements across various employee benefit provisions and related regulations. Key Provisions of the Executive Order Revised Definitions The Executive Order revised the […]
Read moreRecent HIPAA Amendments and Proposed Regulations
In the last year, two significant HIPAA regulations were issued, impacting employer group health plans. This article summarizes the new rules – one under the privacy rule provisions and one under the security rule provisions – and what employers need to know about the current legal status of these rules and how to prepare for […]
Read moreNavigating Employer Leave under Federal FMLA and State Family and Medical Leave Programs
Employers are increasingly faced with the challenge of managing time-off policies amid a complex web of state, local, and federal laws – specifically the interplay between state paid family and medical leave (PFML) programs and the federal Family and Medical Leave Act (FMLA). An opinion letter issued by the U.S. Department of Labor’s (DOL) Wage […]
Read moreReporting Rules Ease Employer ACA Compliance Obligations
Two new federal laws passed at the end of 2024 bring welcomed updates to benefit plan sponsors. Under the Employer Reporting Improvement Act (ERIA) and the Paperwork Burden Reduction Act (PBRA) plan sponsors are no longer required to distribute Forms 1095-B and 1095-C to all covered individuals. The laws also offer employers new protections related […]
Read more2025 RxDC Reporting Deadline
Since the passage of Section 204 of the Consolidated Appropriations Act, 2021 (CAA), referred to as the No Surprises Act (NSA), employers have been required to submit annual prescription drug and health care spending data with the Prescription Drug Data Collection (RxDC) report. The RxDC report collects information about prescription drugs, spending on health care […]
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