Benefits Blast

While recent regulatory developments—including the Departments’ nonenforcement policy, proposed legislation, and new transparency rules—offer employers and plan fiduciaries greater flexibility and potential relief, they also underscore the need for continued vigilance. From ensuring compliance with longstanding MHPAEA obligations to evaluating benefit design changes, managing PBM relationships, and addressing nondiscrimination concerns in self-funded plans, stakeholders must stay proactive and informed to navigate the evolving health and welfare benefits landscape effectively.While recent regulatory developments—including the Departments’ nonenforcement policy, proposed legislation, and new transparency rules—offer employers and plan fiduciaries greater flexibility and potential relief, they also underscore the need for continued vigilance. From ensuring compliance with longstanding MHPAEA obligations to evaluating benefit design changes, managing PBM relationships, and addressing nondiscrimination concerns in self-funded plans, stakeholders must stay proactive and informed to navigate the evolving health and welfare benefits landscape effectively.

As the Supreme Court’s 2024 term comes to a close, we want to highlight several decisions that impact employer-sponsored group health plans. Health plan sponsors will want to monitor the impact of these decisions.

Last month, the United States (U.S.) Court of Appeals for the Fifth Circuit partially upheld a lower court ruling in Braidwood Management, Inc. v. Becerra that invalidated the preventive care mandate under the Affordable Care Act (ACA). 

The IRS recently released Rev. Proc. 2024-25, which provides the inflation-adjusted limits related to health savings accounts (HSAs), high deductible health plans (HDHPs), and excepted benefit health reimbursement arrangements (HRAs) for the 2025 calendar year.

As you may recall back in December of last year, we provided you an update on the current status of the constitutionality of the Affordable Care Act’s (ACA) individual mandate. At that time, we mentioned that the Supreme Court may take the case. The Supreme Court has indeed decided to hear the case.

Earlier this month, the Department of Labor (Department) issued an updated model notice for the Children’s Health Insurance Program (CHIP).

Now that the election is over, it is widely expected that one of the first orders of business for the President-elect will be to significantly modify, replace, or eliminate many Affordable Care Act provisions and/or corresponding regulations.  

On June 25, 2015, in King v. Burwell, the United States Supreme Court upheld the availability of subsidies to individuals in states that use federal healthcare exchanges under the Affordable Care Act.