Compliance Bulletin – Telehealth Exception for HDHP/HSA Plans May Expire Soon

In response to the COVID-19 pandemic, the U.S. Congress enacted legislation that temporarily allowed high deductible health plans (HDHPs) to provide benefits for telehealth services before plan deductibles were met. This relief became effective in 2020 and has been repeatedly extended. It currently applies to plan years beginning before Jan. 1, 2025.
Employers with HDHPs should review their health plan’s coverage of telehealth services to determine if changes should be made for the plan year beginning in 2025. Unless the relief is extended again, HDHPs must impose a deductible on telehealth services to be compatible with HSA contributions.
Also, any changes to telehealth coverage should be communicated to plan participants through an updated summary plan description or a summary of material modifications.
Compliance Overview – ACA Violations – Penalties and Excise Taxes

The Affordable Care Act (ACA) includes numerous reforms for group health plans and creates compliance obligations for employers and health plan sponsors. The ACA, for example, restricts health plans from imposing pre-existing condition exclusions and requires coverage for preventive care services without cost sharing. Some of the reforms for health plans apply to all health plans, while others apply only to non-grandfathered plans or to insured plans in the small group market
Compliance Overview – DOL’s Cybersecurity Program Best Practices for Plan Fiduciaries

The U.S. Department of Labor’s (DOL) Employee Benefits Security Administration (EBSA) has provided
guidance to assist plan fiduciaries and recordkeepers in their responsibilities to manage cybersecurity risks. According to EBSA, pension plans and health and welfare plans covered by the Employee Retirement Income Security Act of 1974 (ERISA) often hold millions of dollars or more in assets and store and/or transfer participants’ personally identifiable data, which can make them tempting targets for cybercriminals.