UBA Content
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Compliance Briefing | March
March ACA Reporting Deadlines for 2025 Calendar Year Plans Each year, employers subject to Affordable Care Act (ACA) reporting must complete several federal filing requirements early in the calendar year. March is the most critical compliance month for ACA reporting because it includes the primary deadline for furnishing employee statements and the electronic filing deadline with…
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Compliance Briefing | February
Updated HIPAA Notice of Privacy Practices Required in 2026 Employers that sponsor self-funded group health plans should prepare for upcoming changes to the HIPAA Notice of Privacy Practices (NPP). Federal privacy rules require group health plans to provide plan participants with an NPP explaining how their protected health information (PHI) is used, disclosed, and safeguarded.…
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Compliance Briefing | January
2026 Transparency in Coverage (TiC) Posting Requirements Employers sponsoring non-grandfathered, self-funded group health plans and health insurance issuers remain responsible for the ongoing Transparency in Coverage (TiC) public posting requirements. Plans must publicly post machine-readable files (MRFs) that disclose in-network negotiated rates, out-of-network allowed amounts, and billed charges for covered items and services. For fully…
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New Law Demands Prescription Drug Pricing Transparency from Pharmacy Benefit Managers
The recently-enacted Consolidated Appropriations Act, 2026 (CAA 2026) promises to significantly shift the information advantage between pharmacy benefit managers (PBMs) and group health plans by requiring semiannual disclosure of vast amounts of prescription drug cost, pricing, utilization, and compensation data. While this law should create much more transparency and insight for employers, plan sponsors and…
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Compliance Recap | Aug. 2024
FEDERAL COURT BLOCKS FTC NON-COMPETE BAN NATIONWIDE: IMPORTANT INSIGHTS FOR EMPLOYERS On August 20, 2024, the U.S. District Court for the Northern District of Texas delivered a crucial ruling, effectively halting the Federal Trade Commission’s (FTC) Rule prohibiting most non-compete agreements. The Rule, which was set to go into effect on September 4, 2024, was…
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Compliance Recap July 2024
FORM 5500 FILING FOR HEALTH AND WELFARE PLANS The Form 5500 series is a component of the Employee Retirement Income Security Act’s (ERISA) reporting and disclosure framework. The Form is used to report information on the qualification of the plan, its financial condition, investments, and its operations. It also guarantees that participants, beneficiaries, and regulators have access…
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Compliance Recap May 2024
PREPARE NOW TO PAY THE PCORI FEE The Patient-Centered Outcomes Research Institute (PCORI) fee funds research that evaluates and compares health outcomes, clinical effectiveness, and the risks and benefits of medical treatments and services. Effective through 2029, the IRS treats this fee like an excise tax, applied to all covered lives, including employees, retirees, spouses,…
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Compliance Recap February 2024
In early February, a federal class action lawsuit was filed against Johnson & Johnson (JNJ) and its plan fiduciaries, alleging overpayment for prescription drugs within its prescription drug plan. The complaint alleges that under the Employee Retirement Income Security Act of 1974 (ERISA), JNJ’s plan fiduciaries are obligated to diligently compare service providers, seek cost-effective options, and…
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Compliance Recap January 2024
NEW EMPLOYEE CLASSIFICATION RULE In January, the Department of Labor (DOL) Wage and Hour Division introduced a rule that changes the way workers are classified under the Fair Labor Standards Act (FLSA). This Final Rule, effective March 11, 2024, offers a more comprehensive test to determine a worker’s status, potentially making it more challenging to classify…
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Compliance Recap December 2023
WORKPLACE POSTERS The U.S. Department of Labor (DOL) enforces the posting of employee notices in the workplace to comply with various DOL statues. The posters are available for free in multiple languages. To determine which posters are needed for your business, the DOL FirstStep Poster Advisor can help. Employers can download and print the posters directly from…
