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Benefit Buzz - January 2024

Zywave, Inc • Jan 16, 2024

Benefit tips brought to you by MFC Benefits, LLC

Learn more about health plans expanding their price comparison tool and the IRS requires electronic filing for ACA reporting for 2024.

HEALTH PLANS MUST EXPAND PRICE COMPARISON TOOL FOR 2024

Beginning in 2024, group health plans and health insurance issuers must expand the internet-based price comparison tool they make available to participants, beneficiaries and enrollees so that it includes all covered items, services and drugs . The purpose of this tool is to provide consumers with real-time estimates of their cost-sharing liability from different providers for covered items and services so they can shop and compare prices before receiving care.

For plan years beginning on or after Jan. 1, 2023, plans and issuers were required to make price comparison information available for 500 shoppable items, services and drugs. For plan years beginning on or after Jan. 1, 2024, price comparison information must be available for all covered items, services and drugs.

Most employers rely on their issuers or third-party administrators (TPAs) to develop and maintain the price comparison tool.

Employers should confirm that their issuers and TPAs will comply with the expanded price comparison tool requirements for the 2024 plan year. Employers should also confirm that their written agreements with issuers and TPAs have been updated to include this compliance responsibility. In addition, self-insured employers should monitor their TPAs’ compliance with this requirement. Unlike fully insured plans, this tool’s legal responsibility stays with a self-insured plan even if its service provider agrees to provide the price comparison tool on its behalf.

IRS REQUIRES ELECTRONIC FILING FOR ACA REPORTING IN 2024

The Affordable Care Act (ACA) requires applicable large employers (ALEs) and employers with self-insured health plans to report information on their health coverage to the IRS and covered individuals.

Before 2024, employers who filed fewer than 250 individual statements under the ACA’s reporting rules could file their returns on paper. However, beginning in 2024, paper filing will only be available to employers who file fewer than 10 information returns with the IRS for the year. Employers must aggregate most information returns, such as Forms W-2 and 1099, to determine if they meet the 10return threshold for mandatory electronic filing.

Due to this change, almost all employers subject to ACA reporting will be required to file their returns electronically beginning in 2024. A hardship waiver may be requested from the electronic filing requirement by submitting Form 8508 to the IRS at least 45 days before the return’s due date.

Employers who have filed paper returns in the past should explore their options for electronic ACA reporting. Although employers can use the IRS’ AIR Program to file their own ACA returns electronically, many rely on outside vendors for electronic reporting due to the AIR Program’s complexity. The standard deadline for electronic ACA reporting is March 31 each year. However, since March 31, 2024, is a Sunday, electronic returns must be filed by April 1, 2024 .

Provided to you by MFC Benefits, LLC

© 2024 Zywave, Inc. All rights reserved

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Benefit Buzz - May 2024

By MFC Benefits, LLC • 15 May, 2024

Learn more about the Prescription Drug Report due date and the Court Ruling on Free Preventive Care. PRESCRIPTION DRUG REPORT IS DUE BY JUNE 1, 2024 Group health plans must annually submit detailed information on prescription drug and health care spending to the federal government. This reporting is referred to as the "prescription drug data collection," or the "RxDC report." The next RxDC report is due by Saturday, June 1, 2024, covering data for 2023. Employers should confirm they are taking steps to comply with this reporting deadline, such as providing information to third-party vendors on a timely basis. The RxDC report is comprised of several files, including those that require specific plan-level information, such as plan year beginning and end dates and enrollment and premium data. It also includes files that require detailed information about medical and pharmacy benefits. RxDC reports must be submitted through an online portal maintained by the Centers for Medicare and Medicaid Services (CMS). CMS'RxDC website includes updated reporting instructions and other reporting resources. Employers commonly use third parties, such as issuers, third-party administrators (TPAs) and pharmacy benefit managers (PBMs), to submit RxDC reports on behalf of their health plans. Employers using third parties to submit RxDC reports must ensure that this reporting responsibility is reflected in a written agreement with the third party. Employers may work with multiple third parties to complete the RxDC report for their health plans. For example, a self-insured employer may use both its TPA and PBM to submit different portions of the RxDC report. A health plan's submission is considered complete if CMS receives all required files, regardless of who submits them. COURT RULING EXPECTED SOON ON FREE PREVENTIVE CARE The 5th U.S. Circuit Court of Appeals is expected to issue a decision within the next few months regarding the constitutionality of the Affordable Care Act's (ACA) preventive care mandate. The ACA requires non-grandfathered health plans and health insurance issuers to cover a set of recommended preventive services without imposing cost-sharing requirements, such as deductibles. In March 2023, the U.S. District Court for the Northern District of Texas struck down a key component of the ACA's preventive care mandate. More specifically, the court ruled that the preventive care coverage requirements based on an A or B rating y the U.S. Preventive Services Task Force on or after March 23, 2010, violate the U.S. Constitution. The Biden administration appealed the District Court's decision to the 5th Circuit. A ruling by the 5th Circuit is expected soon, likely followed by an appeal to the U.S. Supreme Court. It is uncertain whether the 5th Circuit will reverse or uphold the District Court's ruling. However, for now, non-grandfathered health plans and issuers must continue to cover, without cost sharing, the full range of preventive car services required by the ACA. If the 5th Circuit rules that a key component of the ACA's preventive care mandate is unconstitutional, employers will want to consult with their issuers or TPAs to assess the impact on their health coverage. Provided to you by MFC Benefits, LLC © 2024 Zywave, Inc. All rights reserved Download the PDF copy here. Link: http://chrome-extension://efaidnbmnnnibpcajpcglclefindmkaj/https://content.zywave.com/file/b6f7a224-b3a3-4409-a8f2-953f0994d66a/Benefits%20Buzz%20Newsletter%20January%202024.docx Link: http://chrome-extension://efaidnbmnnnibpcajpcglclefindmkaj/https://content.zywave.com/file/b6f7a224-b3a3-4409-a8f2-953f0994d66a/Benefits%20Buzz%20Newsletter%20January%202024.docx