Welcome to our Legislative Review page for employers. For information on legislative and regulatory topics released during Q3 2022, please visit the following links.

YOUR DEDICATED BROKER CAN HELP

We encourage employers to contact their broker directly to discuss recent legislative changes and how they apply to your business.

What Are Employer Responsibilities?

Savoy has created extensive compliance guides to help you stay informed and navigate through the changes. 

Get the details on these top topics:

• Transparency in Coverage Rule Resources
• The Dobbs Decision & Group Health Plans Broadcast

Savoy Academy | Employer Services and Compliance Webinar Series
Attend one of our upcoming Employer Services and Compliance webinars—you may quality to earn 1 HR recertification credit and 1 SHRM Professional Development Credit (PDC) recertification credit for your participation. 

Q4

• October 19 – Annual Required Notices & Electronic Disclosures
• November 16 – Employer Shared Responsibility Reporting
• December 21 – Year in Review & Looking Ahead

Q3 2022 Legislative Review 

Federal

July

• Recent Federal Efforts to Affirm Access to Reproductive Healthcare Services

  • In the wake of the Supreme Court’s decision in Dobbs v. Jackson Women’s Health Organization, there have been two notable federal efforts to establish or reaffirm access to women’s reproductive healthcare services.

August

• Tougher Enforcement of the Contraception Mandate on the Horizon
  • The Departments of Labor, Health and Human Services, and Treasury issued new FAQs clarifying their interpretation of the Affordable Care Act's (ACA) requirement that non-grandfathered health plans provide contraception to participants at no cost.
• 2023 Limits Announced for High Deductible Health Plans and Health Savings Accounts
  • The Internal Revenue Service released updates to the maximum annual 2023 contribution limits for health savings accounts (HSAs) under high deductible health plans (HDHPs).
• ACA Affordability Percentage Decreased for 2023
  • The Affordable Care Act (ACA) considers the affordability of employer-sponsored health plans for the purposes of the shared responsibility rules and the premium tax credit. 
• Biden Administration Proposes New Regulation to Strengthen Health Insurance Coverage Nondiscrimination Protections
  • The new regulation is a revision and expansion of existing federal nondiscrimination requirements and gets its authority from Section 1557 of the Affordable Care Act (ACA).
• President Biden Signs the Inflation Reduction Act
  • President Biden signed the Inflation Reduction Act into law on Tuesday, August 16, 2022. The $750 billion health care, tax and climate bill includes many items specifically reducing the cost of prescription drugs under Medicare Part D. 
• Health Care Provisions in the Inflation Reduction Act
  •  In addition to the act’s deficit reduction measures and the changes it makes to tax law and energy policies, the measure also includes several provisions that have the potential to indirectly impact employer group health plans.
• Transparency in Coverage Update: Issuers and TPAs Can Satisfy Website Posting Requirement
  • On Friday, August 19, 2022, the Departments of Labor, Health and Human Services, and Treasury (the Departments) issued updated Frequently Asked Questions (FAQs) addressing the No Surprises Act and the Transparency in Coverage Rules.

September

• Additional Guidance Issued on Surprise Billing Protections
  • The Consolidated Appropriations Act of 2021 (CAA) introduced numerous protections against surprise billing for plan participants that impact group health plans, health insurance issuers, and providers.
• Medical Loss Ratio Rebate Guidelines
  • The Medical Loss Ratio (MLR) Rebate rules implemented as part of health care reform are designed to ensure that insurance carriers spend no more than a specified percentage of premiums collected on overhead-type expenses.
• Medicare Part D Employer Notification Requirements
  • Plan sponsor notice regarding the organization’s prescription benefits must be provided to any Medicare-eligible person whether due to age or disability and is required for employees, spouses, dependents, those on federal COBRA or New York, New Jersey, Pennsylvania and Delaware continuation including retirees. Notice must be provided before Open Enrollment begins.
• Medicare Part D Creditable vs. Non-Creditable Coverage | Information by Carrier
  • The Employer Medicare Part D Notice is required to be provided prior to October 15, 2022.

This page and its links are informational only and are not intended to constitute legal, tax or business advice. For further information, please refer to your lawyer, business or tax advisor. The accuracy, currency or completeness of the information contained herein is not guaranteed.