Compliance Bulletin | April 2024

Welcome to the April 2024 edition of the Baldwin Bulletin, a compliance newsletter by the Baldwin Regulatory Compliance Collaborative (BRCC).

The Baldwin Bulletin serves as a monthly guide to important regulatory developments, legal news, and employee benefits-related industry happenings designed to keep you abreast of the latest developments.

This month’s issue focuses on important upcoming compliance deadlines and includes our timeline of upcoming compliance requirements, in addition to providing information regarding certain hot-button compliance issues significantly impacting employers.

Upcoming Compliance Deadlines. For information regarding upcoming compliance deadlines for employer-sponsored group health plans, read more here.

2024 HIPAA Privacy and Security Rule Training Calendar. This year’s BRCC Health Insurance Portability and Accountability Act, (“HIPAA”) training calendar is available here.

2024 BRCC Educational Webinar Calendar. The BRCC’s monthly educational webinar series calendar for 2024 is available here.

Medicare Part D Changes May Impact Creditable Coverage Status of Employer Plans. According to The Center for Medicare & Medicaid Services (“CMS”), as of calendar year 2025, the simplified determination  methodology will no longer be valid to determine whether an entity’s prescription drug coverage is creditable. Read more here.

2024 RxDC Reporting. Group health plan sponsors and health insurance issuers are required to submit an annual prescription drug data collection report (“RxDC reporting”) to the Centers for Medicare and Medicaid Services (“CMS”), detailing certain prescription drug benefits and other health care spending data respective of the group health plans they sponsor. Read more here.

ACA Reporting Penalties. The Internal Revenue Service (“IRS”) released Revenue Procedure 2024-14, which decreased the 2025 penalty amounts related to the employer shared responsibility rules under the Affordable Care Act (“ACA”). Read more here.

Medical Expenses Related to Nutrition, Wellness, and General Health. The IRS issued FAQs when costs related to nutrition, wellness, and general health can be paid or reimbursed under a health arrangement. Read more here.

Change Healthcare Cybersecurity Attack. UnitedHealth Group’s Change Healthcare Announces Unprecedented Cyberattack on Financial and Payment Operating Systems. Read more here.

Question of the Month. Our “Question of the Month” concerns whether a provider’s concierge fee is a qualified expense. Read more here. .