Regulatory updates to watch in Q2

These are the health care regulations, announcements and changes to keep on your radar for Q2 2024.

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Staying on top of the legislative changes in an industry as complex and highly regulated as health care can be challenging. That’s why UnitedHealthcare is committed to easing that burden and keeping employers as well as brokers and consultants updated on the legislative changes as they arise.

Here are the changes expected to come down the pike in Q2: 

New short-term limited-benefit guidance

New requirements that impact short-term limited-duration insurance (STLDI) policies, certificates and contracts of insurance were announced in April 2024, and will go into effect for coverage periods beginning on or after Sept. 1, 2024. The changes shorten the term limits for STLDI.

STLDI policies sold or issued before Sept. 1, 2024 (including any subsequent renewals or extensions), may continue under current term limit requirements subject to federal and state law. New plans after the Sept. 1, 2024, effective date must comply with the new requirements. In addition, both existing and new STLDI coverage are subject to updated consumer notice requirements.

Anticipated announcement timing: April 2024

Who it impacts: Employers and individuals with short-term limited-benefit (STLB) policies

High Deductible Health Plan Health Savings Accounts limits

In May 2024, the Internal Revenue Service (IRS) will announce the maximum contribution amounts for 2025 on High Deductible Health Plan Health Savings Accounts (HDHP HSAs). The limit, which is updated annually, applies to all lines of business, including fully insured, self-funded and Level Funded plans.

This update to the max contribution amounts impacts deductibles, out-of-pocket (OOP) limits and contribution limits. It’s also critical to note that those with non-calendar-year plans may need to account for this potential limit change on Jan. 1, 2025.

Anticipated announcement timing: May 2024

Who it impacts: All employers with high deductible plans with an HSA

Consolidated Appropriations Act Prescription Drug Data Collection Reporting

By June 1, 2024, annual reporting on prescription drug data collection (RxDC), which is required of all lines of business under the Consolidated Appropriations Act (CAA), will have been completed. UnitedHealthcare does this on behalf of employers for coverage administered by UnitedHealthcare — and, if there is information needed that is not in our system, UnitedHealthcare collects the missing information from the employers.

It’s critical to note that employers (or third-party administrators on their behalf) will have to submit the reporting if 1) employers haven’t provided their information to UnitedHealthcare and 2) if they have carve-out data (non-UnitedHealthcare coverage).

Anticipated submission timing: June 2024

Who it impacts: All fully insured, self-funded and Level Funded employers

Medical Loss Ratio

In June, UnitedHealthcare will provide fully insured employers an early read on which aggregation sets may receive an annual check due to Medical Loss Ratio.

Please note that this applies to fully insured employers who are in an aggregation set (state, employer size, legal entity) that qualifies (i.e., if their Medical Loss Ratio is less than the percentage noted in the Affordable Care Act, which is 80% for a small group and 85% for a large group). The final report and checks will be sent out by Sept. 30, 2024. 

Anticipated announcement timing: June 2024

Who it impacts: Fully insured employers

Patient-Centered Outcomes Research Institute fee tax

As a reminder, the fee tax for the Patient-Centered Outcomes Research Institute (PCORI) will be due in July. Although it applies to fully insured, self-funded and Level Funded plans, UnitedHealthcare does the filing for fully insured. Other funding types will need to complete their filing to the IRS by July 31, 2024, using Form 720. Fully insured with self-funded account plans (HRA or FSA) need to file for those plans.

Deadline: July 31

Who it impacts: All employers, but UnitedHealthcare files on behalf of fully insured employers

3 items we’re watching closely

  • Affordable Care Act (ACA) guidance on accessibility and Consolidated Appropriations Act (CAA) guidance on air ambulance reporting
  • Supreme Court decision on certain preventive coverage requirements under no-cost preventive care
  • Nondiscrimination requirements under Section 1557 of the ACA (language accessibility, nondiscrimination in access to care and services, treatment of gender as a protected class, training and record keeping)

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