Healthcare Reform
Federal Updates
Retirement Update
Announcements
Reminder: It’s MLR Rebate Time Again!
The ACA requires insurers to submit an annual report to HHS to account for plan costs. If the insurer does not meet the medical loss ratio standards, this means too large a portion of the premiums charged in the previous year went towards the insurer’s administration, marketing, and profit, instead of going toward paying claims and quality improvement initiatives. In such case, the insurer must provide rebates to policyholders. For 2023, insurers must distribute rebates to employer plan sponsors between August 1, 2023, and September 30, 2023.
Employers should keep in mind that if they receive a rebate, there are strict guidelines as to how the rebate may be used or distributed. Generally, any portion of the rebate that is considered ERISA plan assets (e.g., the portion attributable to participant contributions) must be returned to participants in some form within 90 days of receipt.
For more information, download a copy of our publication, Medical Loss Ratio Rebates: A Guide for Employers.
State Alert: Connecticut Announces 2024 Paid Leave Premium and Benefits Maximum Amounts
The state has announced the 2024 maximum contribution and benefit rates payable for CT Paid Leave, which is the state’s paid family and medical leave program.
2024 Contribution Amount
The contribution rate will remain at
0.5%, up to the federal Social Security wage contribution cap, which is $168,600 in 2024 (2023: $160,200). Accordingly, an employee's maximum contribution in 2024 to the state's plan will be
$843
in 2024 (2023: $801). For this purpose, wages used to determine earnings for FICA purposes are counted and may include salary or hourly pay, vacation pay, holiday pay, tips, commissions, and severance pay.
This contribution rate does not apply to private plans; however, private plan coverage cannot cost employees more than what they would be required to pay under the state plan. If the private plan rate exceeds the state plan rate, the employer would need to cover the amount exceeding the state rate. If the private plan is lower than the state rate, employees could not be charged more than the private plan rate.
2024 Weekly Maximum Benefit Amount
The minimum wage for 2024 was announced to be $15.69/hour. As a result, the maximum weekly benefit amount will increase to
$941.40
from $900 effective January 1, 2024, as the weekly benefit is capped at 60 times the CT minimum wage.
For more information about how to calculate an employee’s weekly benefit amount, please visit the CT Paid Leave site here.
CT Paid Leave Site »
Governor Lamont’s Minimum Wage Announcement »
State Alert: Updates to the District of Columbia Paid Family Leave Program
On October 17, 2023, DC’s Office of Paid Family Leave (OPFL) released a new model Notice to Employees that must be posted by February 1, 2024. The model notice is released annually in October. Employers are required to post a physical copy of the notice at each worksite in a conspicuous place where labor notices are customarily posted and send the notice to covered workers who work remotely for posting at their individual worksites.
In addition to posting the notice, covered employers must also provide it in paper or electronic form annually, within 30 days of hiring, and whenever they are aware leave may be needed. More information on posting and notice requirements is available in the OPFL’s DC Paid Family Leave Employer Toolkit .
Additionally, the model notice announces an increased maximum weekly benefit amount of $1,118 (previously $1,049), effective immediately. The employer contribution rate of 0.26% based on the immediate past quarter of gross wages has not changed.
FAQ
As enrollment nears, are there any special compliance concerns or notices required for our wellness program?
State Updates
Connecticut
State Alert: Connecticut Announces 2024 Paid Leave Premium and Benefits Maximum Amounts
The state has announced the 2024 maximum contribution and benefit rates payable for CT Paid Leave, which is the state’s paid family and medical leave program.
2024 Contribution Amount
The contribution rate will remain at
0.5%, up to the federal Social Security wage contribution cap, which is $168,600 in 2024 (2023: $160,200). Accordingly, an employee's maximum contribution in 2024 to the state's plan will be
$843
in 2024 (2023: $801). For this purpose, wages used to determine earnings for FICA purposes are counted and may include salary or hourly pay, vacation pay, holiday pay, tips, commissions, and severance pay.
This contribution rate does not apply to private plans; however, private plan coverage cannot cost employees more than what they would be required to pay under the state plan. If the private plan rate exceeds the state plan rate, the employer would need to cover the amount exceeding the state rate. If the private plan is lower than the state rate, employees could not be charged more than the private plan rate.
2024 Weekly Maximum Benefit Amount
The minimum wage for 2024 was announced to be $15.69/hour. As a result, the maximum weekly benefit amount will increase to
$941.40
from $900 effective January 1, 2024, as the weekly benefit is capped at 60 times the CT minimum wage.
For more information about how to calculate an employee’s weekly benefit amount, please visit the CT Paid Leave site here.
CT Paid Leave Site »
Governor Lamont’s Minimum Wage Announcement »
District of Columbia
State Alert: Updates to the District of Columbia Paid Family Leave Program
On October 17, 2023, DC’s Office of Paid Family Leave (OPFL) released a new model Notice to Employees that must be posted by February 1, 2024. The model notice is released annually in October. Employers are required to post a physical copy of the notice at each worksite in a conspicuous place where labor notices are customarily posted and send the notice to covered workers who work remotely for posting at their individual worksites.
In addition to posting the notice, covered employers must also provide it in paper or electronic form annually, within 30 days of hiring, and whenever they are aware leave may be needed. More information on posting and notice requirements is available in the OPFL’s DC Paid Family Leave Employer Toolkit .
Additionally, the model notice announces an increased maximum weekly benefit amount of $1,118 (previously $1,049), effective immediately. The employer contribution rate of 0.26% based on the immediate past quarter of gross wages has not changed.
Massachusetts
Update to MA PFML Coordination of Benefits “Topping-Off” Rules
Recent legislative amendments will allow employees to supplement (i.e., "top off") benefits received from Massachusetts’ Paid Family and Medical Leave (MA PFML) with any accrued and available paid leave (e.g., sick time, vacation, PTO, personal time) starting with applications filed on or after November 1, 2023.
The combined weekly PFML benefits and supplemented paid leave, whether through an employer’s short-term disability/long-term disability policies or the employee’s PTO, cannot exceed the employee’s average weekly wage. Employers will be responsible for monitoring and ensuring that the combined weekly sum of employer-provided paid leave benefits and PFML benefits does not exceed an employee’s average weekly wage. If the application is filed on or after November 1, 2023, applications filed retroactively for a leave that began before November 1, 2023, are also subject to the new “top off” rule.
Previously, employers who offered the MA PFML program through a private plan had the option to allow their employees to “top off” the benefits from the private plan with accrued paid leave. With the new legislative amendment, private plan employers are now required to provide employees with the top-off option.
For applications filed before November 1, 2023, employees are not allowed to use accrued paid leave on the same days that they are receiving PFML benefits. Employees’ accrued paid leave can only be used during the seven-day unpaid waiting period before the MA PFML benefits begin.
This is a welcome change for employees. Employers should be aware of this important update and work with their payroll division to create an internal procedure, such as the process to calculate the accrued paid leave to supplement MA PFML benefits at an employee’s request. The department has provided helpful information and FAQs regarding this update on the site below.
This material was created by PPI Benefit Solutions to provide accurate and reliable information on the subjects covered but should not be regarded as a complete analysis of these subjects. It is not intended to provide specific legal, tax or other professional advice. The service of an appropriate professional should be sought regarding your individual situation. PPI does not offer tax or legal advice. "PPI®" is a service mark of Professional Pensions, Inc., a subsidiary of NFP Corp. (NFP). All rights reserved.