On November 1, 2024, the Internal Revenue Service (IRS) released Notice 2024-80, which sets forth the 2025 cost-of-living adjustments affecting dollar limits on benefits and contributions for qualified retirement plans. The IRS also announced the health savings account (HSA) and high deductible health plan (HDHP) annual deductible and out-of-pocket expense adjustments earlier this year
Preparing for the End of the COVID-19 Emergency Declarations: Part I. Considerations for COVID-19 Diagnostic Testing Coverage
On January 30, 2023, the Biden Administration announced that it intends for the National Emergency (“NE”) relating to the COVID-19 pandemic to end on May 11, 2023. Shortly after, the Secretary of the Department of Health and Human Services announced the intent to end the Public Health Emergency (“PHE”) on the same day. The end
Departments Provide Relief for 2020 and 2021 Prescription Drug Reporting
On December 23, 2022, the Departments of Labor, Health and Human Services and Treasury (the “Departments”) issued FAQs providing relief from prescription drug and health care spending reporting requirements. The FAQs are available here: https://www.dol.gov/agencies/ebsa/about-ebsa/our-activities/resource-center/faqs/aca-part-56.
As part of the Consolidated Appropriations Act, 2021, group health plans and issuers must annually report to the Departments
Just in the Nick of Time – Congress Grants Second Extension of CARES Act Telehealth/HSA Relief
Recently Congress passed the Consolidated Appropriations Act of 2023 (“2023 CAA”). Among other things, the 2023 CAA extends, for a second time, the telehealth relief provided under the CARES Act. The CARES Act permitted high deductible health plans (“HDHP”) to provide first-dollar telehealth services or other remote care services. This allowed individuals covered under a
Agencies Issue Guidance Requiring Coverage for Over-the-Counter COVID-19 Tests
Beginning January 15, 2022, and through the duration of the public health emergency, insurers and group health plans must cover at-home COVID-19 diagnostic tests available over-the-counter (OTC) without imposing cost-sharing, prior authorization, or other medical management requirements. This requirement stems from the latest guidance issued on January 10, 2022, by the Department of Health and
Agencies Issue COVID-19 Vaccine Incentive Guidance
On October 4, 2021, the Department of Health and Human Services, Department of Labor and Treasury jointly issued FAQs relating to COVID-19 vaccine incentives and surcharges. Under the guidance, employers may provide incentives such as premium discounts or surcharges through group health plans to incentivize COVID-19 vaccines, provided the incentive complies with the activity-only
IRS Releases Guidance on Premium Subsidies for Continuation Coverage under COBRA
On May 18, 2021, the Internal Revenue Service (IRS) released much-anticipated guidance on premium subsidies for continuation coverage under Consolidated Omnibus Budget Reconciliation Act of 1985 (COBRA) provided by the American Rescue Plan Act of 2021 (ARPA). For more information about the ARPA and COBRA subsidies, see Stinson’s previous blog: American Rescue Plan Act Contains
DOL Issues First Ever Cybersecurity Guidance
On April 14, 2021, the Department of Labor’s (DOL) Employee Benefits Security Administration issued guidance on cybersecurity for the first time to help plan sponsors, fiduciaries, service providers, and participants protect personal information and retirement assets. In the guidance, the DOL identifies evaluating cybersecurity practices as part of the plan sponsor’s or other plan fiduciary’s
IRS Guidance on Coronavirus Relief for FSAs, DCAPs, and Cafeteria Plans: Almost Anything Goes
On February 18, 2021, the IRS issued Notice 2021-15, clarifying temporary special rules for cafeteria plans, health flexible spending accounts (“FSAs”), and dependent care assistance programs (“DCAPs”) that were included in the Consolidated Appropriations Act (“CAA”), enacted on December 27, 2020. The Notice also adds temporary opportunities to make changes in health plan coverage under