The 2024 Report highlights ongoing efforts of the departments to enforce protections of MHPAEA and, more specifically, the CAA 2021 nonquantitative treatment limitation (NQTL) comparative analyses requirements.

The DOL and CMS recently released the 2023 Mental Health Parity and Addiction Equity Act (MHPAEA) Enforcement Fact Sheet that summarizes MHPAEA enforcement efforts for fiscal year 2023.

On January 15, 2025, the DOL, HHS, and IRS withdrew proposed rules that would have, among other items, expanded ACA preventive care coverage to include over-the-counter (OTC) contraceptives.

On January 15, 2025, the IRS issued important guidance (Revenue Ruling 2025-4) on the federal income and employment tax treatment of contributions and benefits paid under state-paid family and medical leave (PFML) programs, as well as the related tax reporting requirements.

The annual adjustments relate to a wide range of compliance issues and are based on the percentage increase in the Consumer Price Index for All Urban Consumers (CPI-U) from October of the preceding year.

On January 6, 2025, HHS published proposed regulations relating to HIPAA’s Security Rule requiring numerous additional policies and procedures, imposing substantial ongoing maintenance efforts, and addressing common compliance shortfalls identified by HHS in several recent enforcement investigations. According to the proposed rules, HHS wanted to address the significant technology changes and developments since...

On December 4, 2024, a federal court in the Eastern District of Texas issued a ruling vacating the final rules related to the notice requirement on hospital and fixed indemnity insurance that would have been required for group coverage plan years beginning on or after January 1, 2025.

On December 23, 2024, President Biden signed the Paperwork Burden Reduction Act (PBRA) and Employer Reporting Improvement Act (ERIA) into law. As previously reported in our December 17, 2024, announcement, this legislation makes certain modifications to the ACA’s employer mandate reporting requirements that aim to simplify Forms 1095-B and 1095-C reporting for employers and health insurance providers, as highlighted below.

On December 23, 2024, the DOL, HHS, and IRS (the departments) withdrew proposed rules that would have provided an additional method for individuals to obtain no-cost contraceptive services if their health plan or insurer did not provide such services due to a religious exemption.

On December 2, 2024, the IRS released Notice 2024-83, which announces that the adjusted applicable dollar amount for PCOR fees for plan and policy years ending on or after October 1, 2024, and before October 1, 2025, is $3.47. This is a $0.25 increase from the $3.22 amount in effect for plan and policy years ending on or after October 1, 2023, and before October 1, 2024.