March 2024 Insurance Information & News

Change Healthcare Cybersecurity Incident Affecting Carriers

Multiple health insurance carriers, including AmeriHealth, Geisinger, Guardian, Horizon Blue Cross Blue Shield, and Independence Blue Cross, are experiencing disruptions due to a cybersecurity incident affecting their vendor, Change Healthcare.

While there’s no evidence of data breaches on the carriers’ side, the incident impacts services like accessing explanations of benefits and filling prescriptions.

Carriers are implementing workarounds and alternative methods to minimize disruptions. They are closely monitoring the situation and will provide updates as they become available.

2024 Preventative Care Coverage Changes

The Affordable Care Act (ACA) requires most health plans to cover specific preventive care services for free (no deductibles, co-pays, or co-insurance). These recommendations are updated annually, and for 2024, they include:

Adults: Screening for anxiety, depression (12-18 year olds), and high blood pressure (pregnant women). Additionally, expanded HIV screening and pre-pregnancy/postpartum care.

Women: Counseling to prevent obesity (40-60 years old) and expanded coverage for breastfeeding supplies.

Employers and plan sponsors need to verify their plans cover these services at no cost and adjust their claims procedures accordingly.

E-Filing ACA Reporting Forms

The IRS is changing the game for ACA form submissions:

  • Previously: Employers filing less than 250 forms could submit paper copies.
  • Now: E-filing is mandatory if filing 10 or more combined ACA forms and other tax reports (W-2s, 1099s, etc.).

Challenges faced by employers:

  • Difficulty using the IRS E-filing systems without vendor assistance.
  • Difficulty finding vendors to complete and submit forms on time.
  • Potential “financial hardship” for some employers due to the new requirements.


  1. Request a 30-day extension: File IRS Form 8809 to gain more time.
  2. Consider a waiver:
    • First-time filers: Automatically granted a “first-time waiver” using IRS Form 8508.
    • Undue financial hardship: Submit Form 8508 with justifications and cost estimates from potential vendors.
  3. Contact potential vendors: Get quotes and secure assistance even while waiting for a waiver decision.

Important reminders:

  • Failure to comply can result in penalties of $310 per unfiled form.
  • Employers can still furnish paper copies to individuals, but e-filing to the IRS is mandatory if you meet the threshold.

Consult your tax advisor for further guidance on navigating these changes.

IRS Reduces Employer Mandate Penalties for 2025

The IRS has announced decreased penalties for non-compliance with the ACA’s employer mandate in 2025.

  • The penalty for failing to offer minimum essential coverage to most employees falls to $2,900 per employee (down $70 from 2024).
  • The penalty for not offering affordable coverage to employees who get subsidized coverage elsewhere drops to $4,350 per employee (down $110 from 2024).

This marks the first decrease in penalties since the mandate’s inception in 2015.

REMINDER: Employers with Prescription Drug Plans the Deadline to Report to CMS is March 1st

The Medicare Modernization Act requires employers to annually report whether their prescription drug coverage is “creditable” to the federal government. This deadline is March 1st for plans that started or renewed on January 1st, 2024.

Here’s what employers need to know:

  • Check with the plan carrier to determine the credibility status.
  • No penalty for non-creditable plans.
  • Report using the online form with details like company information, plan type, and estimated Medicare-eligible participants.
  • Participants must be notified of their plan’s creditability status before October 15th each year (typically done during open enrollment or with a separate notice).

Compliance Corner: 10 Health Plan Compliance Items to Keep in Mind for 2024

  1. Online Price Transparency Tools: Must include estimates for ALL covered services.
  2. Telehealth Safe Harbor: Expires December 31, 2024 for non-calendar year plans.
  3. ACA Reporting Statements: Electronic filing mandatory for most employers.
  4. Machine Readable Rx Claims: New file needed with negotiated drug rates (TBD due date).
  5. Compensation Disclosure: Required if receiving at least $1,000 from a group plan.
  6. RxDC Reporting: Due June 3, 2024 with plan-specific information needed.
  7. MHPAEA Compliance: New regulations expected this winter.
  8. “Gag Clause” Prohibition: Annual attestation required by December 31, 2024.
  9. Plan Year Dependent Reporting: Varies by plan renewal date.
  10. Plan Documents and Notices: Distribute to plan participants.
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