Category: Compliance
Compliance Briefing | April
DOL Extends Comment Period on Proposed PBM Fee Disclosure Rule The Department of Labor (DOL) has announced a short extension to the comment period for its proposed rule on pharmacy benefit manager (PBM) compensation transparency. The rule is intended to strengthen disclosure requirements for PBMs and related service providers working with self-insured group health plans subject to…
Filing Form 5500
If your company provides an employee benefit plan governed by the Employee Retirement Income Security Act (ERISA), you are likely obligated to file Form 5500. This annual report discloses key details about your organization’s benefit offerings, such as welfare benefit plans (including medical, dental, life, and disability coverage), retirement plans, fully insured plans, and self-funded…
Compliance Briefing | March
March ACA Reporting Deadlines for 2025 Calendar Year Plans Each year, employers subject to Affordable Care Act (ACA) reporting must complete several federal filing requirements early in the calendar year. March is the most critical compliance month for ACA reporting because it includes the primary deadline for furnishing employee statements and the electronic filing deadline with…
Compliance Briefing | February
Updated HIPAA Notice of Privacy Practices Required in 2026 Employers that sponsor self-funded group health plans should prepare for upcoming changes to the HIPAA Notice of Privacy Practices (NPP). Federal privacy rules require group health plans to provide plan participants with an NPP explaining how their protected health information (PHI) is used, disclosed, and safeguarded.…
Compliance Briefing | January
2026 Transparency in Coverage (TiC) Posting Requirements Employers sponsoring non-grandfathered, self-funded group health plans and health insurance issuers remain responsible for the ongoing Transparency in Coverage (TiC) public posting requirements. Plans must publicly post machine-readable files (MRFs) that disclose in-network negotiated rates, out-of-network allowed amounts, and billed charges for covered items and services. For fully…
ACA Update: IRS Announces 2027 Cost-Sharing Limits
On January 29, 2026, the U.S. Department of Health and Human Services (HHS) officially released the maximum cost-sharing limits for the 2027 plan year. These figures represent a significant 13.2% increase over the 2026 limits, marking a substantial shift in potential out-of-pocket expenses for plan participants. 2027 Maximum Out-of-Pocket Limits For 2027, the maximum annual…
IRS Increases PCORI Fee Rate
The Internal Revenue Service (IRS) has issued Notice 2025-61, announcing a significant increase to the Patient-Centered Outcomes Research Institute (PCORI) fee amount. Employers with self-insured health plans and health insurance issuers must take note of the new rate and upcoming compliance deadlines. What is the New PCORI Fee Amount? The PCORI fee is increasing to…
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…