29 pages. "This 2024 Final Letter provides updates on operational and technical guidance for the 2024 plan year for issuers seeking to offer qualified health plans (QHPs), including stand-alone dental plans (SADPs), in the Federally-facilitated Exchanges (FFEs) or the Federally-facilitated Small Business Health Options Programs (FF-SHOPs). It also describes how parts of this 2024 Final Letter apply to issuers in State-based Exchanges on the Federal Platform (SBE-FPs)."   MORE >>

"The most recent instructions state that submissions can only be made through the HIOS system. Email submissions are no longer accepted. Employers that have yet to establish a HIOS account are encouraged to create one as soon as possible."   MORE >>

"Nongrandfathered plans must continue to cover COVID-19 vaccines obtained from in-network providers at no cost, as these were added as [ACA] preventive services by the CARES Act."   MORE >>

"Starting in 2024, employers filing 10 or more returns in aggregate must file their Forms 1094-C and 1095-C electronically. This ends the option to file by paper for virtually all employers, and therefore employers will need to prepare to engage with an ACA reporting vendor to complete next year's filing via the IRS AIR system."   MORE >>

"Health plan participants, employers and medical providers harmed by a [MEWA] operating in 36 states will begin to finally receive payments related to more than $54 million in unpaid health claims ... [T] he MEWA's court-appointed independent fiduciary [ Receivership Management Inc. will] distribute more than $6.75 million in recovered assets ... [An] investigation by [EBSA] found fiduciary breaches by AEU Holdings, Black Wolf Consulting and Veritas PEO [.] " [ Walsh v. AEU Benefits, LLC , No. 17-7931 (N.D. Ill. Mar. 28, 2023)]   MORE >>

"[EBSA] has identified MHPAEA ... enforcement as a key priority in its current a fiscal year enforcement plan.... Although many diagnosticians and courts consider autism a neurological rather than psychological disorder, EBSA often interprets and enforces MHPAEA as applicable to Applied Behavior (ABA) therapy and other treatment for autism."   MORE >>

"[J]ust 31% [of employers surveyed] are satisfied with network access for behavioral health care services. In addition, only 34% of employers said that their behavioral health care directors accurately reflected the providers available to their plan members."   MORE >>

"Insurers must cover the costs of breast cancer screenings for people at high risk of developing the disease under a new [Pennsylvania law] ... Advocates for health care access said the law ... is a positive, though limited, step toward making crucial medical tests more affordable. They urged further action in this vein, something that typically requires lawmakers to negotiate with the commonwealth's powerful health insurance industry."   MORE >>

"Under current law, eligible California employees are entitled to a minimum of twenty-four hours, or three days, of paid sick leave per year. SB 616 proposes to expand the entitlement to fifty-six hours, or seven days."   MORE >>

"[C]overage of these drugs may cost $500 per plan member per year (ALL plan members, not just per obese adult). This assumes only half of those clinically eligible use these drugs. So, let's say the drugs do provide the intended net benefits long term. Will the employer who made the investment be the same one to reap the rewards of a healthier employee?"   MORE >>

"Victims of severe storms, tornadoes and flooding in Florida from April 12 to April 14, 2023, now have until August 15, 2023, to file various individual and business tax returns and make tax payments ... [I]ndividuals and households ... that reside or have a business in Broward County qualify for tax relief."   MORE >>

"[1] 401(k) and 403(b) fee cases continue.... [2] No good deed goes unpunished: 1947 pension trust creates $38 million ERISA liability.... [3] Oops! Board action alone did not terminate severance plan.... [4] DOL weighs in on supplemental life insurance: evidence of insurability.... [5] Beneficiary/slayer denied retirement plan benefits."   MORE >>

"[A] healthy 65-year-old male retiree with [a Medicare Advantage plus Part D] plan will spend $134,000 for healthcare in his remaining lifetime (equating to $90,000 of savings in today's dollars), down from $137,000 in 2022. A 65-year-old female retiree with the same coverage will spend approximately $155,000 on healthcare expenses over the course of her lifetime ($100,000 in savings today), down from $158,000 in 2022."   MORE >>

"[T]he increase in defense costs linked to the rise of jury trials in this context isn't just a question of the relative cost of conducting a jury trial relative to the cost of bench trials. Instead, it is driven by the fact that the possibility of jury trials is likely to increase the number of trials and the amount sought in settlement of these types of cases.... However, from a merits perspective, it is not entirely clear that jury trials in this context are by definition a bad thing."   MORE >>