Compliance Bulletin | June 2023

Welcome to the June 2023 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 compliance deadlines that will apply this year, in addition to providing employers with information regarding certain hot-button compliance issues significantly impacting employers over the next several months.

Upcoming 2023 Compliance Deadlines. For information regarding upcoming compliance deadlines for employer-sponsored group health plans, including our compliance timeline explaining key compliance deadlines during June – December 2023. Read more here.

Outbreak period set to end. The Outbreak Period end date of July 10, 2023, is fast approaching.  Read more here.

IRS Announces 2024 HSA/High Deductible Health Plan Limits. The IRS has released Revenue Procedure 2023-23, announcing health savings account and high deductible health plan limits for 2024. Read more here.

PCORI Fee Payment Reminder. Employers sponsoring self-insured health plans, take note that the annual PCORI fee payment is due on July 31 for plans with plan years ending during 2022.  Read more here.

IRS Issues Guidance on FSA Substantiation Requirements. The IRS recently issued a Chief Counsel Advice Memorandum that provides important reminders about the claims substantiation requirements for flexible spending accounts (FSAs).  Read more here.

Sun Life Report Provides Insights into Self-Insured Plan Expenses. An analysis of claims data prepared by Sun Life yielded many interesting findings, including that million-dollar claims per million covered employees increased by 15% last year and by 45% from 2019 to 2022.  Read more here.

Payroll Tax Withholding for Washington Cares Fund to Begin July 1, 2023. Payroll tax withholding under the Washington Long Term Care Act will begin on July 1, 2023, for companies with employees in Washington State.  Read more here.

Question of the Month. Our “Question of the Month” concerns the applicability of ERISA to telehealth benefits. Read more here.