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Tenth Circuit Court of Appeals Hands Down a Big Win for ERISA Preemption After several failed attempts by pharmacy benefit managers (“PBM”) to challenge state laws regulating PBMs, the 10th Circuit Court of Appeals (in Pharmaceutical Care Management Association v. Mulready) handed down a big win for PBMs and, by extension, self-funded ERISA plans, when […]

IRS Issues Affordability Percentage Adjustment for 2024 The Internal Revenue Service (IRS) has released Rev. Proc. 2023-29, which contains the inflation adjusted amounts for 2024 used to determine whether employer-sponsored coverage is “affordable” for purposes of the Affordable Care Act’s (ACA) employer shared responsibility provisions and premium tax credit program. As shown in the table […]

I believe in playing to my strengths, and building relationships is very important to me both in life, business and investing. One advantage is that it provides the ability to network. For many years, I’ve been told that I am effective at networking, which I define as the exchange of information, ideas and resources. At […]

On July 12, 2023, the IRS, DOL and HHS (collectively, “the Agencies”) released proposed regulations that modify the conditions for hospital indemnity and other fixed indemnity insurance to be considered an “excepted benefit.”  Maintaining “excepted benefit” status is important for fixed indemnity plans, as it exempts them from having to comply with the ACA’s insurance […]

FICA Reduction Redux – IRS Issues Guidance on Wellness Indemnity Payments On June 9, 2023, the IRS released OCC Memo 202323006, which advises that wellness indemnity payments under a fixed indemnity insurance policy are wages for purposes of Federal Insurance Contributions Act (FICA) taxes, Federal Unemployment Tax Act (FUTA) taxes, and federal income tax withholding […]

Purpose, Passion and Principles  Do you have a mission in life that is consistent with your purpose?   Do you have a strong principled alignment of your personal and professional life?   I learned that before I figured out what I wanted to do, I needed to figure out WHO I wanted to be. I am striving […]

Employers that sponsor self-insured group health plans, including health reimbursement arrangements (HRAs) should keep in mind the upcoming July 31, 2023 deadline for paying fees that fund the Patient-Centered Outcomes Research Institute (PCORI) via Form 720, which was recently updated and released by the IRS.  As background, the PCORI was established as part of the Affordable […]

In Rev. Proc. 2023-23, the IRS released the inflation adjusted amounts for 2024 relevant to Health Savings Accounts (HSAs) and high deductible health plans (HDHPs). The table below summarizes those adjustments and other applicable limits.   2024 2023 Change Annual HSA Contribution Limit(employer and employee) Self-only: $4,150 Family: $8,300 Self-only: $3,850 Family: $7,750 Self-only: +$300 Family: […]

Up to 18 million people may no longer be eligible for Medicaid coverage now that states are required to resume annual Medicaid renewals, following a “break” and relaxed social service benefits rules during the pandemic. Because The Families First Coronavirus Response Act (FFCRA) declared a public health emergency, states were prohibited from disenrolling Medicaid recipients. […]