On March 9, 2023, the IRS released updated penalty amounts for 2024 related to the employer shared responsibility (pay or play) rules under the Affordable Care Act (ACA). For calendar year 2024, the adjusted $2,000 penalty amount is $2,970 … Continue reading
Category Archives: Affordable Care Act
New FAQs on ACA’s Cost-sharing Limit and No Surprises Act
On July 7, 2023, the Departments of Labor, Health and Human Services, and the Treasury (Departments) issued frequently asked questions (FAQs) on the implementation of the Affordable Care Act’s (ACA) overall cost-sharing limit and the No Surprises Act’s (NSA) protections … Continue reading
DOL Issues Guidance on Preventive Care Court Order
On March 30, 2023, the United States District Court for the Northern District of Texas issued an order in Braidwood Management Inc. v. Becerra (“Braidwood”), vacating any and all actions taken by the DOL and other federal agencies (in the … Continue reading
Agencies Issue Guidance on the End of the COVID-19 Emergencies (Revised based on the President’s Signature of H.J.Res. 7 on April 10, 2023)
On January 30, 2023, President Biden issued a Statement of Administration Policy announcing his intent to end the COVID-19 national and public health emergencies on May 11, 2023. However, on April 10, 2023, the President signed H.J.Res. 7, which … Continue reading
ACA Pay or Play Penalties Will Increase for 2024
Pay or Play Affordability Percentage Decreased for 2023
On Aug. 1, 2022, the IRS issued Revenue Procedure (Rev. Proc.) 2022-34 to index the contribution percentages in 2023 for determining the affordability of an employer’s plan under the Affordable Care Act (ACA). For plan years beginning in 2023, employer-sponsored … Continue reading
2023 Open Enrollment Checklist
To prepare for open enrollment, group health plan sponsors should be aware of the legal changes affecting the design and administration of their plans for plan years beginning on or after Jan. 1, 2023. Employers should review their plan documents … Continue reading
Agencies Release First Rule on the No Surprises Act
On July 13, 2021, the DOL, HHS, and IRS released a joint Interim Final Rule implementing specified provisions of the No Surprises Act, a new law included within the Consolidated Appropriations Act, 2021. The No Surprises Act addresses, among other … Continue reading
President Trump Issues Executive Orders Intending to Lower the Cost of Prescription Drugs
On July 24, 2020, President Trump issued several Executive Orders intending to lower prescription drug costs by (1) modifying anti-kickback laws to lower drug prices, (2) reducing trade barriers to increase importation of drugs and lower prices, and (3) improving … Continue reading
CMS Extends Transition Relief for Non-Compliant Plans through 2021
On January 31, 2020 the Centers for Medicare & Medicaid Services (CMS) announced a one-year extension to the transition policy (originally announced November 14, 2013 and extended six times since) for individual and small group health plans that allows issuers … Continue reading
Congress Expected to Pass Spending Bill that Repeals Three Major ACA Taxes, Extends PCORI
On December 17, 2019, the House and Senate agreed to a bipartisan legislative package of spending bills to avoid a government shutdown. This package of bills is collectively referred to as the Further Consolidated Appropriations Act, 2020 (the “Act”). The … Continue reading