Compliance Bulletin | September 2024

Welcome to the September 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 HIPAA training calendar is available here.

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

Civil Monetary Penalty Annual Index from Health & Human Services for OCR & CMS. The Department of Health and Human Services (“HHS”) has updated its regulations to reflect required annual inflation-related increases to the civil monetary penalty (“CMP”) amounts in its statutes and regulations, under the Federal Civil Penalties Inflation Adjustment Act Improvements Act of 2015.

The adjusted civil monetary penalty amounts apply to penalties assessed on or after August 8, 2024, if the violation occurred on or after November 2, 2015. Read more here.

Department of Labor (“DOL”) Released Bi-Annual Children’s Health Insurance Plan (“CHIP”) Notice. The Children’s Health Insurance Program Reauthorization Act of 2009 (“CHIPRA”) allows states to offer financial help to eligible low-income families to afford employer-sponsored health coverage. This help often comes in the form of premium assistance subsidies. Employers who offer a group health plan and have employees living in a state that provides these premium assistance subsidies must send eligible employees a CHIP notice each year. Read more here.

The Emergency Medical Treatment & Labor Act (“EMTALA”) and State Conflict on Emergency Abortion Ban. In 1986, Congress enacted the Emergency Medical Treatment & Labor Act (“EMTALA”) to ensure public access to emergency healthcare services regardless of an individual’s ability to pay for such access. Read more here.

Client Update Regarding Medicare Part D Program Redesign. On April 1, 2024, the Centers for Medicare and Medicaid Services (“CMS”) released the Final Part D Redesign Program Instructions for the 2025 calendar year. Read more here.

How Employers Can Assist with Menopause Care. A discussion that was once a sensitive topic for women’s reproductive health, more employers and employees are now openly discussing menopause and associated care. Read more here.

Question of the Month. Our “Question of the Month” concerns which notices are needed for small business as per federal law. Read more here.