Beginning December 27, 2021, covered service providers (brokers and consultants) of ERISA-covered group health plans, regardless of size, must provide responsible plan fiduciaries information on direct and indirect compensation in writing. On December 30, 2021, the DOL released Field Assistance Bulletin No. 2021-03, which provides guidance on this new broker transparency law. While many questions […]

The IRS recently released Notice 2022-04, announcing the adjusted applicable dollar amount used to determine the PCOR fee for plan years ending on or after October 1, 2021 and before October 1, 2022. The PCOR filing deadline is August 1, 2022 for all self-funded medical plans and some HRAs for plan years (including short plan […]

The IRS released final Instructions for Forms 1094-C and 1095-C for calendar year 2021 reporting. Background Applicable large employers (“ALEs”) must furnish Form 1095-C to full-time employees and file Form 1094-C and all 1095-Cs with the IRS. ALEs offering a self-insured group health plan must also furnish Forms 1095-C to covered employees or other primary […]

On November 23, 2021, the Office of Personnel Management and the Departments of Labor, the Treasury, and Health and Human Services (collectively, “the Departments”) published interim final regulations under the Consolidated Appropriations Act, 2021 (“CAA”) that require group health plans to submit an annual report to the federal government on prescription drugs and health care […]

On December 2, 2021, the Biden administration issued a nine-pronged plan to combat COVID-19 as the winter months approach and the new Omicron variant poses risk of new infections. The plan covers: Boosters for adults Vaccinations to protect children and keep schools open Expanded free at-home testing International travel protections Workplace protections Rapid response teams […]