Employers subject to the DBRA and the SCA should review their current fringe benefit administration to ensure that all fringe benefit payments have been properly annualized. Any unfunded benefit plans that covered employers are crediting against their fringe benefit obligations should be submitted to the DOL for approval.

In a recent decision, Texas Medical Association v. U.S. Department of Health and Human Services (“HHS”), a U.S. district court in Texas vacated portions of the regulations implementing the federal independent dispute resolution (“IDR”) process under the No Surprises Act (“NSA”).

As a reminder, insurance carriers are required to satisfy certain medical loss ratio (“MLR”) thresholds. This generally means that for every dollar of premium a […]

Medicare Part D Notification Requirements Employers that provide prescription drug benefits are required to notify Medicare-eligible individuals annually as to whether the employer-provided benefit is creditable or non-creditable so that these individuals can decide whether or not to delay Part D enrollment. Also, the employer must annually notify CMS as to whether or not the employer plan is creditable.

The IRS recently announced in Revenue Procedure 2023-29 that the Affordable Care Act (“ACA”) affordability indexed amount under the Employer Shared Responsibility Payment (“ESRP”) requirements […]