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Key Health Plan Notice Updates for 2023, 2024 and Beyond

health planEmployers should be aware of updates to several model notices that can be used to comply with certain disclosure requirements that apply to their group health plans under federal laws.

Federal agencies provide these model notices to aid compliance and periodically update them to reflect changes to the law or changes to the information contained in the notices.

This Compliance Bulletin provides details on key health plan notice updates for 2023, 2024 and beyond that the agencies intend to make.


IRS Released Updated Penalty Amounts For 2025

IRS Releases ACA Pay-or-Play PenaltiesOn Feb. 12, 2024, the IRS released updated penalty amounts for 2025 related to the employer shared responsibility (pay-or-play) rules under the Affordable Care Act (ACA). For calendar year 2025, the adjusted $2,000 penalty amount is $2,900, and the adjusted $3,000 penalty amount is $4,350. This is a decrease from the penalty amounts for the 2024 calendar year, which are $2,970 and $4,460, respectively.


7 Key Employee Benefits Trends in 2024

7 Key Employee Benefits Trends in 2024This article discusses the 7 key employee benefits trends in 2024. Attracting and retaining employees has challenged employers since the onset of the COVID-19 pandemic. In 2024, the labor market is expected to cool slightly; however, competition for talent will remain. As such, employers must remain agile and adapt to developing labor and market trends that will shape the market in 2024. In particular, current labor challenges are forcing employers to find ways to balance rising health care costs and inflation while providing employees with benefits they value and need. Understanding this year’s key employee benefits trends can help employers attract and retain talented individuals in an evolving labor market.


Upcoming ACA Reporting Deadlines

Upcoming ACA Reporting DeadlinesEmployers subject to Affordable Care Act (ACA) reporting under Internal Revenue Code Sections 6055 or 6056 should prepare to comply with the upcoming ACA reporting deadlines in early 2024. For the 2023 calendar year, covered employers must:

  • Furnish statements to individuals by March 1, 2024 (an alternative method of furnishing statements to covered individuals is available in certain situations); and
  • File returns with the IRS by Feb. 28, 2024, or April 1, 2024, if filing electronically. Beginning in 2024, employers that file at least 10 returns during the calendar year must file electronically.

Penalties may apply if employers are subject to ACA reporting and fail to file returns and furnish statements by the applicable deadlines.


2023 Year-end Checklist for Employee Benefit Plans

2023 Year-end Checklist for Employee  Benefit PlansAlthough the end of the year is a busy time, employers should continue to prioritize compliance requirements for their employee benefit plans. There are several benefits-related tasks that employers should make sure are completed by the end of 2023, such as:

  • Submitting a gag clause attestation for their health plans (or confirming that an issuer or third-party administrator (TPA) submits the attestation);
  • Amending plan documents for discretionary changes made for 2023;
  • Confirming annual notices have been provided, such as the Children’s Health Insurance Plan (CHIP) notice; and Performing any necessary nondiscrimination testing.

Affordable Care Act 2024 Compliance Checklist

Affordable Care Act 2024 Compliance ChecklistThe Affordable Care Act (ACA) made a number of reforms to group health plan coverage when it was enacted in 2010. Since then, changes have been made to various ACA requirements that employers should be aware of. These changes include annual cost-of-living increases to certain ACA dollar limits, extensions to ACA reporting deadlines and updates to preventive care coverage guidelines.


What Employers Should Know About Hush Trips and Workcations

Hush Trips and WorkcationsThe traditional concept of a vacation often involves escaping the daily grind and relaxing in a faraway destination. However, the landscape of work and leisure has recently been transformed, with remote and hybrid work becoming more prevalent. This shift has led to workcations, where remote employees take vacations while still working, and “hush trips,” which are workcations not disclosed to the company.

This article explains hush trips and what employers should know about remote employees taking them.


Medicare Supplement Plans for 2024

Medicare AdvantageIf you are getting close to your 65th birthday, you are likely preparing to enroll in Medicare. Enrolling in Medicare and figuring out how to decrease your out-of-pocket health care expenses can be daunting. A Medicare supplement plan for 2024 can save you money and provide peace of mind.

Original Medicare, which consists of Medicare Part A and Part B, typically does not cover all of an individual’s health care costs. In order to fill the gap, many individuals purchase a Medicare supplement plan. Medicare supplement plans, also known as Medigap policies, are policies that can be purchased to cover expenses that Medicare does not pay.


Final Forms and Instructions for 2023 ACA Reporting Released

Final Forms and Instructions for 2023ACA Reporting ReleasedThe IRS has released final 2023 forms and instructions for reporting under Internal Revenue Code Sections 6055 and 6056:

  • 2023 Forms 1094-B and 1095-B (and instructions) will be used by providers of minimum essential coverage, including self-insured plan sponsors that are not applicable large employers (ALEs), to report under Section 6055.
  • 2023 Forms 1094-C and 1095-C (and instructions) will be used by ALEs to report under Section 6056 as well as for combined Section 6055 and 6056 reporting by ALEs who sponsor self-insured plans.

Health Care Spending Expected to Exceed Overall Economic Growth

Health Care Spending Expected to Exceed Overall Economic GrowthA recent report from the Centers for Medicare and Medicaid Services (CMS) predicted that the average growth in national health expenditures would outpace average gross domestic product (GDP) growth from 2022 to 2031, at 5.4% and 4.6%,respectively. Per person spending is also expected to increase to an annual rate of 4.8% from 2022 to 2031. This is above pre-COVID-19-pandemic growth rates for per person spending, which averaged 3.9% per capita between 2014 and 2019. CMS anticipated that the growth in national and per person health care spending would contribute to an increase in the health care spending share of the GDP.


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