Employers 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.
On 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.
This 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.
Employers 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.
Although 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.