Staying on top of health plan compliance can be tricky, but fear not! This blog post breaks down some key updates for 2024 quarter one, focusing on transparency and other important regulations.

Transparency Takes Center Stage

The Transparency Rule continues to be a major focus. Employers and health plans must ensure they:

• Maintain machine-readable healthcare pricing data files accessible to the public (ongoing requirement).
• Offer consumer-friendly online tools for all cost-sharing estimates for all covered services and drugs, effective January 1, 2024.

This increased transparency empowers consumers to make informed decisions about their healthcare.

ACA Reporting Goes Electronic (Mostly)

For most employers with 10 or more employees, 2024 marks the year for electronic filing of Forms 1094-C and 1095-C with the IRS. The deadline for electronic submissions is April 1st, with a February 28th deadline for paper submissions (for those who qualify).

Air Ambulance Claims Reporting: Still in Limbo

The final ruling on air ambulance claims reporting is yet to be issued. While a proposed rule was introduced in September 2021, deadlines for 2023 data have been postponed. We expect a final ruling with specific reporting requirements and deadlines in the future. Stay tuned for updates! In the meantime, check here to keep informed:

• CMS Air Ambulance Data Collection Page: https://www.cms.gov/marketplace/about/oversight/other-insurance-protections/air-ambulance-data-collection

Other Compliance Updates to Consider

• Mental Health Parity and Addiction Equity Act (MHPAEA): Expect stricter enforcement of parity rules between mental health/substance use disorder (MH/SUD) benefits and medical/surgical benefits. Plans should maintain a documented NQTL analysis for compliance.  This analysis demonstrates how the plan addresses parity requirements. It should be readily available upon request from government agencies or plan participants.
• High-Deductible Health Plans (HDHPs): Increased contribution limits for HSAs paired with HDHPs apply in 2024. Employers offering HDHPs can extend telehealth coverage without impacting HSA eligibility until December 31, 2024.

• Individuals with self-only coverage under a qualifying HDHP: The maximum HSA contribution limit is now $4,150, which is an increase of $300 from the 2023 limit.
• Individuals with family coverage under a qualifying HDHP: The maximum HSA contribution limit is now $8,300, which is an increase of $550 from the 2023 limit.
• Prescription Drug Data Collection (RxDC) Reporting: The deadline to submit RxDC reports for 2023 data is June 1, 2024. This year, more detailed data submission is required due to the “aggregation restriction” being enforced by CMS.

Stay Informed

Remember, this is not an exhaustive list, and specific requirements can vary depending on your plan and state. Here are some helpful resources:

• Department of Labor (DOL): https://www.dol.gov/
• Department of Health and Human Services (HHS): https://www.hhs.gov/
• Internal Revenue Service (IRS): https://www.irs.gov/

For personalized compliance guidance, consider consulting with a qualified health plan advisor or attorney.