DOL Updates Model Employer CHIP Notice The U.S. Department of Labor (DOL), through its Employee Benefits Security Administration (EBSA), has released a new model Employer CHIP Notice with information current as of March 17, 2025. Background As a reminder, the Children’s Health Insurance Program Reauthorization Act of 2009 (CHIPRA) imposes an annual notice requirement [...]
Employers Should Start Preparing for 2025 RxDC Reporting Group health plans and health insurance issuers must annually submit detailed information on prescription drug and health care spending to the Centers for Medicare & Medicaid Services (CMS). This reporting is referred to as the “prescription drug data collection” (or “RxDC report”). The next RxDC report [...]
OSHA Proposes Heat Injury and Illness Prevention Standard On Aug. 30, 2024, the U.S. Department of Labor’s (DOL) Occupational Safety and Health Administration (OSHA) published a notice of proposed rulemaking in the Federal Register to protect workers from heat injury and illness. If finalized, the new standard would apply to all employers conducting indoor [...]
Deadline for California 2024 Pay Data Reporting Is May 14, 2025 Each year, group health plan sponsors are required to complete an online disclosure form with the Centers for Medicare & Medicaid Services (CMS), indicating whether the plan’s prescription drug coverage is creditable or non-creditable. This disclosure requirement applies when an employer-sponsored group health [...]
Deadline for California 2024 Pay Data Reporting Is May 14, 2025 Employers with 100 or more employees and/or 100 or more workers hired through labor contractors, in each case at least one of whom is in California, must file annual workforce pay data reports with the state Civil Rights Department (CRD). 2024 pay data [...]
FAQs Provide New Guidance on Gag Clause Attestation Requirement On Jan. 14, 2025, the Departments of Health and Human Services, Labor and the Treasury (Departments) issued frequently asked questions (FAQs) on the implementation of several federal transparency requirements, including the prohibition on gag clauses. Background Federal law prohibits group health plans and health insurance [...]
HHS Proposes Changes to HIPAA Security Rule to Strengthen Cybersecurity for Electronic PHI On Dec. 27, 2024, the U.S. Department of Health and Human Services (HHS) released a proposed rule that would modify the HIPAA Security Rule to strengthen cybersecurity protections for electronic protected health information (ePHI). Although the changes are substantial, they are [...]
NLRB Asserts Stay-or-Pay Provisions Are Unlawful On Oct. 7, 2024, the General Counsel (GC) of the National Labor Relations Board (NLRB) issued a memorandum asserting that certain “stay-or-pay” provisions unlawfully infringe on employee’s rights under the National Labor Relations Act (NLRA). Background In 2023, the NLRB GC issued a memorandum declaring that overbroad noncompete [...]
2024 Employment-related Ballot Measures Passed by Voters On Nov. 5, 2024, voters in several states decided on ballot measures that will impact and change the workplace in 2025 and beyond. This Compliance Bulletin provides an overview of the employment-related ballot measures voters passed in 2024. The ballot measures included the following topics: Minimum wage [...]
State-run Retirement Savings Programs A growing number of states have established state-facilitated retirement savings programs to help their constituents save for retirement. Most of the programs share common features, such as requiring employers who do not offer their own retirement plans to enroll their employees into these state-run programs automatically. Often, the employers that [...]
