Category: Compliance
Compliance Recap | November 2025
THE ANNUAL GAG CLAUSE ATTESTATION DUE DEC. 31, 2025 Under the rules adopted by Congress in the Consolidated Appropriations Act, 2021 (CAA), group health plans and health insurance issuers of both fully insured and self-funded plans must certify that their contracts with providers, networks, third-party administrators (TPAs), pharmacy benefit managers (PBMs), or other service providers…
Meeting the ERISA Deadline: Handling MLR Rebates
Employers with insured health plans may have received a Medical Loss Ratio (MLR) rebate from their health insurance carrier this year. Rebates were required for plans not meeting the 2024 MLR standards and had to be issued by September 30, 2025, either as premium credits or lump-sum payments. If any part of the rebate qualifies…
Compliance Recap | October 2025
2026 PENALTIES FOR FAILURE TO FILE OR FURNISH ACA REPORTING FORMS The IRS has announced the 2026 penalties for failure by Applicable Large Employers (ALEs) to file or furnish Affordable Care Act (ACA) reporting Forms 1095-C and 1094-C for the 2025 tax year. Amounts can increase significantly depending on how late the filing is or…
Compliance Recap | September 2025
UNDERSTANDING AND DISTRIBUTING MLR REBATES Insurance carriers must issue Medical Loss Ratio (MLR) rebates by September 30 when too much of the prior year’s premiums went to administrative costs or profit instead of claims and quality improvements. Employers who received MLR rebate checks will need to determine how much—if any—belongs to the plan and its…
What Brokers Should Be Doing Now to Get Clients ACA-Ready
How to position yourself as a trusted ACA compliance advisor For brokers and benefits advisors, Q4 planning doesn’t start in October. It starts now. September marks a critical moment in the annual ACA compliance cycle, when employers begin thinking about year-end strategies, benefits renewals, and how to avoid last-minute reporting panic. That makes now the perfect…
Compliance Recap | August 2025
NORTH CAROLINA PASSES NEW PBM LAW On July 10, 2025, North Carolina Governor Josh Stein signed into law the Act Supporting Community Retail Pharmacies and Improving Transparency (“the SCRIPT Act”). The sweeping law regulating pharmacy benefit managers (PBMs) in North Carolina is designed to improve transparency, strengthen consumer protections, and support community pharmacies. While most…
Compliance Recap July 2025
THE ONE BIG BEAUTIFUL BILL ACT IMPACT ON EMPLOYEE BENEFITS The One Big Beautiful Bill Act of 2025 (OBBBA) introduces permanent changes to a range of employee benefits, creating a more stable and generous framework for employers and employees. HDHPs and HSAs Telehealth Services: High-deductible health plans (HDHPs) can now permanently cover telehealth before deductibles…
Compliance Recap | July 2025
THE ONE BIG BEAUTIFUL BILL ACT IMPACT ON EMPLOYEE BENEFITS The One Big Beautiful Bill Act of 2025 (OBBBA) introduces permanent changes to a range of employee benefits, creating a more stable and generous framework for employers and employees. HDHPs and HSAs Telehealth Services: High-deductible health plans (HDHPs) can now permanently cover telehealth before deductibles…
Compliance Recap | June 2025
SUPREME COURT AFFIRMS PREVENTIVE CARE PROTECTIONS UNDER THE ACA The U.S. Supreme Court has upheld a critical component of the Affordable Care Act (ACA), reinforcing the requirement that health insurers provide coverage for preventive services recommended by a federal expert panel. The decision ensures that Americans will continue to have access to early detection and…
Compliance Recap | May 2025
CONSOLIDATED APPROPRIATIONS ACT 2024 RXDC REPORTING DEADLINE The Centers for Medicare & Medicaid Services (CMS) has reaffirmed that the instructions for reporting 2024 Prescription Drug Data Collection (RxDC) remain unchanged from 2023. The deadline for employers and plan sponsors to submit 2024 data is Sunday, June 1, 2025. Overview of RxDC Reporting Requirements Each year, employers sponsoring…