On December 23, 2024, President Biden signed into law two important pieces of legislation that aim to ease the administrative and reporting burdens on health plan sponsors and insurance providers under the Affordable Care Act (ACA). The Paperwork Burden Reduction Act and the Employer Reporting Improvement Act bring significant changes to the way employers must
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New Year Brings New Automatic Enrollment and Escalation Requirements for Some Recently Adopted 401(k) and 403(b) Plans
The SECURE 2.0 Act of 2022 requires certain 401(k) and 403(b) plans to include automatic enrollment and escalation features for the first plan year beginning after December 31, 2024, meaning that for those plans with a calendar plan year, the new year brought a new compliance obligation.
Beginning on January 1, 2025, 401(k) and 403(b)…
Annual Limits on Qualified Plans for 2025

On November 1, 2024, the Internal Revenue Service (IRS) released Notice 2024-80, which sets forth the 2025 cost-of-living adjustments affecting dollar limits on benefits and contributions for qualified retirement plans. The IRS also announced the health savings account (HSA) and high deductible health plan (HDHP) annual deductible and out-of-pocket expense adjustments earlier this year…
IRS Introduces Official Section 83(b) Election Form
On November 7, 2024, the IRS introduced Form 15620, a new standardized form for taxpayers opting to make a Section 83(b) election. Previously, taxpayers needed to send a letter to the IRS with the required information to make the Section 83(b) election effective.
When a taxpayer receives restricted property (usually in the form of…
DOL Settlements Remind Employers to Avoid Collecting Premiums Until Evidence of Insurability is Approved
The U.S. Department of Labor (DOL) announced two settlements with major insurance companies this month that highlight the importance of employers avoiding the collection of group life insurance premiums from employees until the insurer has approved them for coverage, including receipt and approval of required evidence of insurability (EOI). These settlements follow two similar agreements…
HHS Supports Reproductive Health Care Privacy by Modifying the HIPAA Privacy Rule
The Department of Health and Human Services’ (“HHS”) Office for Civil Rights recently published a final rule (the “Final Rule“) which provides additional privacy protections related to the use and disclosure of reproductive health care information. Covered entities (e.g., health plans) and their business associates must comply with all of the provisions of…
Annual Limits on Qualified Plans for 2024
On November 1, 2023, the Internal Revenue Service (IRS) released Notice 2023-75, which sets forth the 2024 cost-of-living adjustments affecting dollar limits on benefits and contributions for qualified retirement plans. The IRS also announced the health savings account (HSA) and high deductible health plan (HDHP) annual deductible and out-of-pocket expense adjustments earlier this year…
IRS Announces Delay of Implementation of SECURE 2.0 Act’s Roth Catch-up Contribution Provision for Two Years
As signed into law, Section 603 of the SECURE 2.0 Act of 2022 (“SECURE 2.0”) required that effective as of January 1, 2024, participants in 401(k) plans, 403(b) plans, or governmental 457(b) plans, who were age 50 or older and whose Social Security wages for the previous year exceed $145,000 (indexed), only be permitted to…
Preparing for the End of the COVID-19 Emergency Declarations: Part II. Considerations for COVID-19 Vaccine Coverage
As explained in part I of our Preparing for the End of the COVID-19 Emergency Declaration series, the Public Health Emergency (“PHE”) and National Emergency (“NE”) are coming to a close. While the Biden Administration had initially announced its intent to end the NE on May 11, 2023, on April 10, 2023, President Biden signed…
Preparing for the End of the COVID-19 Emergency Declarations: Part I. Considerations for COVID-19 Diagnostic Testing Coverage
On January 30, 2023, the Biden Administration announced that it intends for the National Emergency (“NE”) relating to the COVID-19 pandemic to end on May 11, 2023. Shortly after, the Secretary of the Department of Health and Human Services announced the intent to end the Public Health Emergency (“PHE”) on the same day. The end…