Compliance Bulletin | January 2024

Welcome to the January 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 2024 timeline of 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 and our 2024 compliance calendar, read more here.

ACA Non-English Language Requirements Update.  CMS has announced the issuance of updated “County Data for Culturally and Linguistically Appropriate Services” (“CLAS County Data”) that will become effective for plan years beginning January 1, 2025. The CLAS County Data is used to assist plan sponsors in complying with the ACA’s requirement that certain group health plan materials be provided in a “culturally and linguistically appropriate manner.” For more information, read more here.

Mental Health Parity Litigation Ruling. In a significant ruling, the 10th Circuit Court of Appeals held in favor of a plaintiff, who brought a claim under the Mental Health Parity and Addiction Equity Act (MHPAEA) against Health Net Life Insurance Company by successfully arguing that the health plan’s medical necessity criteria for intermediate level mental health treatment benefits are more stringent than those applied to the plan’s intermediate level medical or surgical benefits. Read more here.

DOL Issues 2024 Adjusted Penalty Amounts. The Department of Labor has released its 2024 inflation-adjusted civil monetary penalties that may be imposed on employers for violating certain federal employment and benefit related laws, including ERISA. Read more here.

Another HIPAA Settlement Announced. The Health and Human Services’ Office of Civil Rights has reached a $160,000 settlement agreement with Optum Medical Care of New Jersey for violating HIPAA’s Right of Access rules by failing to timely respond to requests from several individuals for their medical records. Read more here.

2024 HIPAA Privacy and Security Rule Training Calendar. The BRCC’s HIPAA training calendar has been issued for the coming year.   Read more here.

2024 BRCC Educational Webinar Calendar. The BRCC’s monthly educational webinar series calendar for 2024 has been announced.  Read more here.

Question of the Month.  Our “Question of the Month” concerns the definition of an ERISA benefit plan. Read more here


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