News & Analysis as of

Benefit Plan Sponsors Reporting Requirements

Davis Wright Tremaine LLP

How SECURE 2.0 Options Impact Form W-2 and Form 1099-R Reporting

IRS reminds employers that implementing certain optional retirement plan provisions of SECURE 2.0 affect Form W‑2 and Form 1099‑R reporting starting in 2023 - The IRS recently issued Fact Sheet 2024‑18 to highlight how...more

Alston & Bird

Major Changes Coming to the Qualified Professional Asset Manager Exemption

Alston & Bird on

Our Employee Benefits & Executive Compensation and Investment Funds Teams break down the increased compliance requirements – and compliance costs – qualified professional asset managers (QPAMs) face under the Department of...more

Hall Benefits Law

Employer Involvement Rendered Disability Insurance Plan Subject to ERISA, Despite Lack of Intent

Hall Benefits Law on

In Steigleman v. Symetra Life Ins. Co., 2023 WL 7413668 (D. Ariz. 2023), a court considered whether a package of various welfare benefit insurance policies an individual business owner arranged for herself and her employees...more

Bricker Graydon LLP

The Gift That Keeps on Giving: New IRS Guidance on Roth Employer Contributions

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The Internal Revenue Service (IRS) gave plan sponsors an early Christmas gift with the release of new guidance late last year addressing several key provisions contained in SECURE 2.0. A welcome portion of the notice was...more

Venable LLP

Fast-Approaching Deadlines for ACA Reporting and Similar State Reporting - January 2024

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This alert describes upcoming reporting deadlines under the Affordable Care Act (ACA) and under state laws that require similar reporting. Generally, reporting that relates to health coverage in one calendar year is due early...more

Bricker Graydon LLP

Gag Clause Attestations due December 31, 2023

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If you sponsor a group health plan, make sure you set a calendar alert before the winter holidays to submit the annual gag clause prohibition compliance attestation. Under the Consolidated Appropriations Act of 2021 (CAA),...more

McDermott Will & Emery

Better Than a Snow Day: The PBGC Provides One-Time Section 4010 Reporting Waiver

McDermott Will & Emery on

Acknowledging uncommon market conditions, the Pension Benefit Guaranty Corporation (PBGC) announced Technical Update Number 23-1 (the Update), which provides a one-time waiver of certain reporting requirements for some...more

Bradley Arant Boult Cummings LLP

Making the First “Gag Clause” Attestations: A Quick Reference Guide

Under the Consolidated Appropriation Act of 2021 (CAA), group health plans and health insurance issuers are prohibited from entering into agreements with service providers restricting certain information that the plan may...more

Verrill

Gag Clauses – New Guidance and Litigation Will Inform Compliance

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Certain provisions of the Transparency in Coverage Final Regulations and the Consolidated Appropriation Act, 2021 (“CAA”) require group health plans and/or their vendors to report information to federal agencies. On December...more

Ballard Spahr LLP

Reminder: Reporting Requirement for Health Care Costs One Month Away

Ballard Spahr LLP on

Health plan sponsors and health insurers will need to report prescription drug and other health plan costs (RxDC reporting) for 2022 by June 1, 2023. Unlike the RxDC reporting requirements for 2020 and 2021, this deadline is...more

Woodruff Sawyer

Agencies Release Revised Instructions for 2022 Reference Year RxDC Reporting

Woodruff Sawyer on

On March 3, 2023, federal agencies released revised Prescription Drug Data Collection (RxDC) Reporting Instructions applicable to the 2022 reference year. RxDC reporting for the 2022 reference year is due on or before June 1,...more

Venable LLP

Fast-Approaching Deadlines for ACA Reporting and Similar State Reporting

Venable LLP on

This alert describes upcoming reporting deadlines under the Affordable Care Act (ACA) and under state laws that require similar reporting. Generally, reporting that relates to health coverage in one calendar year is due early...more

Verrill

A Last-Minute Gift – Prescription Drug Reporting Grace Period and Good Faith Relief

Verrill on

In a move akin to last-minute gift-giving, the Departments of Labor, Health and Human Services, and the Treasury (the “Departments”) released FAQ 56 on December 23, 2022, which provides relief regarding the Prescription Drug...more

Ogletree, Deakins, Nash, Smoak & Stewart,...

Federal Regulators Offer Employer Health Plans Last-Minute Relief on Prescription Drug Reporting

Employers have a reprieve from the challenging December 27, 2022, deadline for reporting 2020 and 2021 prescription drug cost information to the U.S. Department of Health and Human Services (HHS). ...more

Keating Muething & Klekamp PLL

Benefits Monthly Minute UPDATE: RxDC Reporting Relief

On December 23, 2022, FAQs were released outlining late-breaking RxDC Reporting Relief. Of note - 1. For the 2020 and 2021 data submissions that are due by December 27, 2022, the Departments will not take enforcement...more

McDermott Will & Emery

IRS Issues Final Regulations Extending ACA Information Reporting Deadlines, Clarifies Additional ACA Issues

McDermott Will & Emery on

On December 15, 2022, the Internal Revenue Service (IRS) finalized regulations regarding Information Reporting of Health Insurance Coverage and Other Issues Under Internal Revenue Code (Code) Sections 5000A, 6055 and 6056...more

Laner Muchin, Ltd.

Reminder: Deadline for Prescription Drug and Certain Medical Claim Reporting is December 27, 2022

Laner Muchin, Ltd. on

The 2021 Consolidated Appropriations Act (CAA) established new transparency requirements for group health plans to report specific information about prescription drugs and health care spending to the Centers of Medicaid and...more

Holland & Hart - The Benefits Dial

What Happens in a Small Town Stays in a Small Town … Until the DOL Doubles Down on Mental Health Parity Compliance

The Department of Labor (DOL), the Department of Health and Human Services (HHS), and the Department of Treasury (collectively, the Departments) recently issued their joint report to Congress regarding their Mental Health...more

Ogletree, Deakins, Nash, Smoak & Stewart,...

Making a List, Checking It Twice: Year-End Guidance on Drug Cost Reporting

Employers and their benefit administrators have more detail and a more convenient way to submit “top 50” lists and other data - but no more time to comply with - daunting prescription drug cost reporting requirements in the...more

Williams Mullen

PODCAST: Williams Mullen's Benefits Companion - New Prescription Drug and Health Coverage Reporting Requirements

Williams Mullen on

On this episode of Williams Mullen's Benefits Companion, host Brydon DeWitt discusses the Biden administration’s interim final rule that requires health plans to report prescription drug and health coverage costs and its...more

Fisher Phillips

Don’t Forget Medicare Prescription Drug Reporting to CMS

Fisher Phillips on

Most employers who offer plans that include prescription drug coverage are acutely aware of the requirement to notify individuals as to the creditable status of that coverage before October 15 each year. However, many are...more

Fisher Phillips

Departments Delay Enforcement of Transparency Disclosure Requirements

Fisher Phillips on

Group health plan sponsors soon will face daunting new disclosure and transparency requirements under multiple laws including the Affordable Care Act (ACA), the No Surprises Act (the Act) and the Consolidated Appropriations...more

Ogletree, Deakins, Nash, Smoak & Stewart,...

Agencies Issue FAQs on Required Comparative Analysis of Nonquantitative Treatment Limitations

The Consolidated Appropriations Act (CAA), 2021 had far-reaching effects on employee benefit plans. One of the more onerous changes introduced by the CAA relates to the Mental Health Parity and Addiction Equity Act of 2008...more

Fisher Phillips

Overview Of Employee Benefit Provisions In The Consolidated Appropriations Act

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The Consolidated Appropriation Act of 2021 was signed into law on December 27, 2020 and is an impressive 5,593 pages. According to the Senate Historical Office, the Act is the longest bill ever passed by Congress. Buried...more

Faegre Drinker Biddle & Reath LLP

Fee Disclosure Rules Will Soon Apply to Group Health Plans

Buried in the year-end Consolidated Appropriations Act (CAA) is a provision that requires group health plan brokers and consultants to make comprehensive fee disclosures similar to those that apply to retirement plans. As...more

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