Compliance Bulletin – Medicare Part D Changes May Impact Creditable Coverage Status of Employer Plans

The Inflation Reduction Act of 2022 (IRA) includes several cost-reduction provisions affecting Medicare Part D plans, which may impact the creditable coverage status of employer-sponsored prescription drug coverage beginning in 2025.
Employers that provide prescription drug coverage to individuals who are eligible for Medicare Part D must inform these individuals and the Centers for Medicare and Medicaid Services (CMS) whether their prescription drug coverage is creditable, meaning that the employer’s prescription drug coverage is at least as good as Medicare Part D coverage
Compliance Bulletin – Mental Health Parity Compliance Remains a Key Focus in 2024

The federal government is continuing its efforts to improve access to mental health and substance use disorder (MH/SUD) care in 2024, with a top enforcement priority being compliance with the Mental Health Parity and Addiction Equity Act (MHPAEA) for employer-sponsored health plans.
MHPAEA is a federal law that prevents group health plans and health insurance issuers that provide MH/SUD benefits from imposing more restrictions on those benefits than what generally applies to comparable medical or surgical benefits.
Compliance Bulletin – Form 5500 Deadline is July 31st

Each year, employers that are subject to the Employee Retirement Income
Security Act of 1974 (ERISA) must electronically file an annual report
(Form 5500) for each employee benefit plan they maintain unless a filing
exemption applies.
Employers with employee benefit plans that operate on a calendar year
basis must file their annual reports for 2023 with the U.S. Department of
Labor (DOL) by July 31, 2024. An employer may extend this deadline by
2.5 months (until Oct. 15, 2024) by filing Form 5558 with the IRS by July
31, 2024.
Compliance Tracker – April

A | Filing Deadline for Affordable Care Act (ACA) Returns (Electronic Reporting) – April 1, 2024
Applicable large employers (ALEs) and non-ALEs with
self-insured plans must file their ACA returns with the
IRS by April 1, 2024, if filing electronically. Beginning
in 2024, most employers are required to file their ACA
returns electronically.
B | EEO-1 Data Collection Begins – April 30, 2024
Employers with 100 or more employees and certain
federal contractors must file EEO-1 reports with the
Equal Employment Opportunity Commission (EEOC)
each year. The EEOC’s portal for submitting EEO-1 reports
from 2023 is scheduled to open on April 30, 2024.
C | Posting Period Ends for OSHA Form 300A – April 30, 2024
Employers may remove their OSHA Form 300A posting
at any time on or after April 30, 2024. This form, which
summarizes workplace data from 2023, must be posted
from Feb. 1, 2024, until April 30, 2024