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Higginbotham Sample Compliance Overview

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Top Health Plan Compliance Issues for 2024

Key Developments - 2024 •

Employers should be aware of the top compliance issues that impact their health plan coverage for 2024. Some of these compliance issues are established requirements for employers, such as the expanded electronic reporting requirement under the Affordable Care Act (ACA). Other compliance issues are anticipated developments employers should monitor, such as new regulations under the Mental Health Parity and Addiction Equity Act (MHPAEA).

Additional transparency requirements for health plans, including expansion of the cost comparison tool

Continued focus on MHPAEA enforcement

Other top health plan compliance issues employers should be aware of in 2024 include:

Federal appeals court decision regarding ACA’s coverage mandate for preventive care benefits

Lowered threshold for ACA electronic reporting

New health plan transparency requirements;

Ongoing litigation regarding the ACA’s requirement to cover preventive care services without cost sharing;

Possible expansion of the ACA’s contraceptive coverage mandate; and

Proposed legislation at state and federal levels to regulate pharmacy benefit managers (PBMs).

Other Possible Changes •

New state and federal regulation of PBM practices to help control health plan spending

New state insurance mandates for fully insured health plans

Revised HIPAA privacy and security rules Extension of telehealth exception for high deductible health plans (HDHPs)

LINKS AND RESOURCES • Final rule lowering the threshold for electronic ACA reporting beginning in 2024

• • Website for submitting prescription drug data collection (RxDC) report • Proposed rule from August 2023 on MHPAEA compliance

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