"Only HSA-eligible individuals can establish and contribute to an HSA ... Qualifying medical expenses must be incurred after HSA established for tax-free distribution ... There is no requirement that a tax-free HSA distribution be taken in the same year that the medical expense was incurred.... Loss of HSA eligibility does not affect ability to take tax-free medical distributions ... Prohibition of double dipping ... HSA rollovers and transfers ... Estate planning considerations."  MORE >>

"The IRS COBRA regulations generally do not permit such midyear increases. A group health plan may require a COBRA qualified beneficiary to pay an amount that does not exceed 102% of the 'applicable premium' for the coverage. ... The applicable premium must be computed and fixed prior to the start of a 12-month 'determination period' and generally cannot be changed until the next determination period."  MORE >>

"Employers and plan sponsors who wish to take advantage of this simplified ACA reporting should ... [1] [U]pdate any existing processes as necessary, including the need to annually post the notice and keep it posted for the required time period. [2] Establish a process for timely responding to requests to obtain a copy of the form ... [3] Make sure you still comply with any state reporting requirements (e.g., CA, MA, NJ, RI, DC) that may apply to your workforce. [4] Remember that you still have an obligation to file the Forms 1095-C and 1095-B with the IRS[.]"  MORE >>

"The key elements of the Act: [1] impose on certain health plans targeted consumer cost-sharing limitations for selected pharmaceuticals used to treat delineated chronic conditions; [2] impose mandatory licensing and regulation of PBMs, including constraints on to-be-defined PBM conflicts of interest; and [3] require PBMs and pharmaceutical manufacturers to comply with detailed cost and pricing data reporting requirements[.]"  MORE >>

"Not-for-profit organizations in Michigan must assess and adjust their policies to align with the revised ESTA requirements ... While the law is already in effect, small not-for-profits have until October 1, 2025, to implement the necessary changes. It's crucial to use this time effectively to achieve full compliance."  MORE >>

"As a result of a flawed Inflation Reduction Act (IRA), CMS is authorized to set a maximum fair price (MFP) that takes effect as early as nine years post-approval for certain small molecule drugs with high Medicare expenditures.... [If] the IRA had established equivalent timelines for price-setting small molecule drugs and biologics at the same timeframe -- 13 years -- half of the drugs chosen for price controls in 2026 would not have been selected. Policy changes are needed to grant small molecule drugs the same timelines as biologics, allowing beneficiaries to maintain more affordable, consistent access to necessary treatments for longer."  MORE >>