Let our team help you navigate the ever-changing benefits compliance landscape each month. Check out this month’s latest alerts, additional updates, and resources hot off the press:
Employee Benefits Compliance Alerts
This month’s Compliance Matters newsletter provides a comprehensive review of the following topics. To obtain your copy, please use the form below to download.
- Evolving Considerations for Gender Non-Discrimination
- San Francisco HCSO Top-Off Payments Due Soon
- Departments Provide Additional Guidance for Contraception Preventive Services
- 2024 State Regulation Series: Hawaii Prepaid Healthcare Act
Download this month’s alerts
Additional Updates & Resources
Rules for Association Health Plans Rescinded
In December 2023, the Department of Labor (DOL) proposed rescinding 2018 regulations for Association Health Plans (AHPs), that were originally intended to expand the reach and use of AHPs. The 2018 regulations created a more flexible “commonality of interest” test that would expand the pool of individuals eligible to participate in an AHP. In 2019, a court vacated key portions of the regulations, including the “commonality of interest” test. The DOL states that rescinding the AHP regulations will “resolve and mitigate any uncertainty” regarding their status and ensure that guidance provided on this issue aligns with ERISA’s “text, purposes, and policies.”
2024 Federal Poverty Level Guidelines Updated
In January, the Department of Health and Human Services (HHS) released the 2024 federal poverty guidelines. Employers can use the federal poverty level (FPL) to calculate affordability under §4980H (the Employer Mandate) for applicable large employers to comply with the Affordable Care Act (ACA) FPL safe harbor and avoid penalties for providing unaffordable coverage. FPL refers to any of the poverty guidelines in effect within six months before the first day of the plan year of the applicable large employer’s health plan. The FPL is typically updated in late January, so a calendar year plan will generally rely upon the FPL of the previous year, while plans beginning in February or later can rely upon the current year’s FPL.
New Marketplace Notice Released
Recently, the Department of Labor posted updated Marketplace notices to the applicable website. The Marketplace notice provides information about coverage options and premium tax credits available through the Marketplace and has been updated to provide more detail about Marketplace open enrollment and special enrollment periods, but otherwise is substantially the same. It is recommended that the updated notice be used for distribution to new hires going forward. The Marketplace notice is required to be provided to employees within 14 days of hire.
2024 State-Mandated Short-Term Disability Rates – At a Glance
Six states, and Puerto Rico, have mandated short-term disability for workers. Some of those states update benefits, wage caps and contribution amounts annually. Below is a quick reference guide for short-term disability benefits and rates in 2024.
| State | Maximum Benefit Amount | Maximum Benefit Length | Payroll Deduction Amount | Maximum Annual Salary Cap |
|---|---|---|---|---|
| California | $1,620 | 52 weeks | 1.1% | None |
| Hawaii | $798 | 26 weeks | 0.5% | $59,081.47 |
| New Jersey | $1,055 | 26 weeks | 0.0% | $42,300 |
| New York | $170 | 26 weeks | 0.5% | None* |
| Puerto Rico | $113 | 12 weeks | 0.6% | $9,000 |
| Rhode Island | $1,043 / $1,359** | 30 weeks | 1.1% | $84,000 |
*There is no salary cap, but a maximum annual payroll contribution of $355.25 exists.
**Employee Only/Employee with Dependents
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