Skip Navigation
  • Careers
  • Report a Claim
  • Contact Us
Risk Strategies Logo
  • Industries

    • Agriculture
    • Architects & Engineers
    • Aviation
    • Cannabis
    • Construction
    • Dental
    • Education
    • Entertainment
    • Financial Services
    • Fine Art
    • Healthcare
    • Law Firms
    • Marine & Yacht
    • Nonprofit & Human Services
    • Private Equity
    • Public Sector
    • Real Estate
    • Relocation
    • Transportation
    • Waste & Recycling
    • Wineries
  • Solutions

      • Captives
      • Casualty
      • Cyber
      • Environmental
      • International
      • Management Liability
      • Property
      • Surety
      • Employee Benefits Overview
      • Benefit Administration and Technology
      • Benefits Compliance Support
      • Data & Analytics
      • Human Capital Advisory Services
      • International Benefits
      • Absence Management & Ancillary Programs
      • Voluntary & Lifestyle Benefits
      • Medicare
      • Financial & Wealth Overview
      • Life Insurance
      • Private Client Services Overview
      • Homeowners
      • Flood
      • Collections
      • Umbrella & Excess Liability
      • Auto
      • Collector & Exotic Car
      • Boat & Yacht
      • Travel Medical & Trip Insurance
      • Family Office
      • Cyber Insurance - Family Office
      • Cyber Insurance - Individuals
      • Specialty Coverages
      • Private Client Risk Resource Center
    • Reinsurance
      • Risk Management Services Overview
      • Analytics
      • Claims Management & Advocacy
      • Loss Control
      • Safety Consulting Services
      • Pro Safety Training Courses
      • Workers’ Comp: Premium Review & Recovery
  • Consulting

    • Consulting Overview
    • Actuarial Services
    • Healthcare Claim Audit Services
    • Health and Welfare
    • Mergers and Acquisitions
    • Pharmacy Consulting
    • Retirement Benefits
  • News and Insights

    • All Insights
    • Blog
    • Emergency Resource Centers
    • Employee Benefits Compliance Center
    • Events
    • Media Coverage
    • State of the Market Reports
    • Press Releases
    • Private Client Resources
    • Webinars
  • Company

    • About Us
    • Annual Report
    • Careers
    • Culture and Values
    • Diversity, Equity & Inclusion
    • Environmental, Social, & Governance
    • General Terms of Business
    • Leaders
    • Local Expertise
    • Mergers & Acquisitions
    • Recognition & Awards
    • Risk Strategies Foundation
    • Transparency and Disclosures
  • Join Us
    • Careers
    • Mergers & Acquisitions
  • Industries
    • Agriculture
    • Architects & Engineers
    • Aviation
      • Aviation Business Insurance - Manned Risk
      • Non-Owned Aviation
      • Unmanned Aerial System and Drones
    • Cannabis
    • Construction
      • Alternative Solutions
      • Financing & Pre-Construction
      • Insurance Solutions
      • Risk Management
      • Surety
    • Dental
      • Insurance for Dental Professionals
      • Dental Malpractice Insurance
      • BOP Insurance - Dental Practices & DSOs
      • Dental School Graduates
      • Dental Associates & Hygienists
      • Dental Practice Owners
      • Dental Service Organizations (DSOs)
    • Education
      • Employee Benefits for Education
      • Property, Casualty & Liability for Education
      • Student Health & Wellness
        • Student Health Brokerage and Consulting
        • Student Health Plan Administration
        • Student Health Insurance Plans
        • Solutions for Student Athletes
        • Student Health & Wellness Tools
        • Special Risk Insurance
    • Entertainment
      • Film & Television
      • Advertising Production Wrap Ups
      • Advertising/PR
      • Event Cancellation & Non-Appearance
      • Music & Touring
      • Theatrical Production & Live Performance 
      • Venue Insurance
    • Financial Services
      • Asset Managers
      • Banks & Non-Bank Lending
      • Collections
      • Consumer Financial Services
      • Financial Tech
      • Insurance Companies
    • Fine Art
      • Artists
      • Artist Endowed Foundations
      • Auction Houses
      • Fine Art Packers / Shippers / Warehouses
      • Galleries
      • Museums
      • Private Art Dealers / Advisors
      • Private Collectors
    • Healthcare
      • Employee Benefits - Healthcare
      • Managed Care / Stop Loss
      • Medical Malpractice
      • Property & Casualty - Healthcare
      • Reinsurance
    • Law Firms
    • Marine & Yacht
      • Boat & Yacht For Individuals
      • Commercial & Recreational Marine Businesses
        • Marine Businesses
        • Sailing Organizations - Burgee Program
      • Jackline Insurance Solutions for Cruisers
      • Mega Yachts
      • One-Design Insurance Program
      • Crew Medical Insurance
      • Sailors Health Insurance Program
      • US Sailing Insurance Solutions
    • Nonprofit & Human Services
    • Private Equity
      • Crypto Companies
    • Public Sector
      • Public Safety Organizations & Municipalities
    • Real Estate
      • Commercial
      • Community Associations
      • Hospitality
      • Residential / Habitational
      • REITs
      • Retail
      • Specialty Programs
    • Relocation
      • Domestic Household Goods
      • Expat Renters & Living Insurance
      • Relocation Claims Service
      • International Household Goods
      • Supplemental Movers Coverage
      • Temporary Living Insurance
      • Vacant Home
    • Transportation
      • Business Auto Insurance
      • Last Mile Delivery
      • While Under Dispatch Insurance
      • Forwarding & Brokering
      • Workers' Compensation
    • Waste & Recycling
    • Wineries
  • Solutions
    • Commercial Insurance
      • Captives
      • Casualty
        • Analytics
        • Auto Liability & Physical Damage
        • Captives & Alternative Risk Financing
        • Claims Advocacy & Loss Control
        • Excess Liability
        • General Liability
        • Product Recall
        • Workers' Compensation
      • Cyber
        • Cyber Resolute
        • Cyber Risk Assessment and Analytics
        • Cyber Risk Response & Claims Advocacy
        • Cyber Insurance - Family Office
        • Cyber Insurance - Individuals
      • Environmental
        • Contractors Pollution Liability
        • Environmental Excess
        • Environmental Liability Transfer
        • Environmental Liability - Healthcare
        • Environmental Liability - Higher Education
        • Pollution Legal Liability
        • Environmental Liability - Private Equity
        • Professional Environmental Liability Insurance
        • Real Estate Development
        • Remediation Cost Cap
        • Secured Creditor Protection for Lenders
        • Underground Storage Tanks
      • International
      • Management Liability
        • Management Liability - Entertainment
        • Management Liability - Financial Institutions
        • Management Liability - Healthcare
        • Management Liability - Real Estate
      • Property
        • Builder's Risk
        • Property Claims Services
        • Inland Transit and Ocean Cargo
        • Natural Hazard Catastrophe Modeling
        • Political Violence and Terrorism
        • Property Damage & Business Interruptions Valuations
        • Property Loss Prevention and Control
      • Surety
    • Employee Benefits
      • Employee Benefits Overview
      • Benefit Administration and Technology
      • Benefits Compliance Support
      • Data & Analytics
      • Human Capital Advisory Services
      • International Benefits
      • Absence Management & Ancillary Programs
      • Voluntary & Lifestyle Benefits
      • Medicare
    • Financial & Wealth
      • Financial & Wealth Overview
      • Life Insurance
    • Private Client Services
      • Private Client Services Overview
      • Homeowners
      • Flood
      • Collections
      • Umbrella & Excess Liability
      • Auto
      • Collector & Exotic Car
      • Boat & Yacht
      • Travel Medical & Trip Insurance
      • Family Office
      • Cyber Insurance - Family Office
      • Cyber Insurance - Individuals
      • Specialty Coverages
      • Private Client Risk Resource Center
    • Reinsurance
    • Risk Management Services
      • Risk Management Services Overview
      • Analytics
      • Claims Management & Advocacy
      • Loss Control
      • Safety Consulting Services
      • Pro Safety Training Courses
      • Workers’ Comp: Premium Review & Recovery
  • Consulting
    • Consulting Overview
    • Actuarial Services
    • Healthcare Claim Audit Services
    • Health and Welfare
    • Mergers and Acquisitions
    • Pharmacy Consulting
    • Retirement Benefits
  • News and Insights
    • All Insights
    • Blog
    • Emergency Resource Centers
      • Cybersecurity
      • Earthquake
      • Hurricane
      • Pandemic
      • Riot & Civil Unrest
      • Severe Storms
      • Violence & Active Shooter
      • Wildfire
      • Winter Weather
    • Employee Benefits Compliance Center
    • Events
    • Media Coverage
    • State of the Market Reports
    • Press Releases
    • Private Client Resources
    • Webinars
  • Company
    • About Us
    • Annual Report
    • Careers
    • Culture and Values
    • Diversity, Equity & Inclusion
      • BeHEARD Series
      • DE&I Structure
      • Employee Resource Groups
    • Environmental, Social, & Governance
    • General Terms of Business
    • Leaders
    • Local Expertise
    • Mergers & Acquisitions
    • Recognition & Awards
    • Risk Strategies Foundation
    • Transparency and Disclosures
      • General Terms of Business
      • Conflict of Interest Policy
      • Compensation Disclosure
      • Enterprise Risk Management
  • Join Us
    • Careers
      • Benefits & Wellness
      • Investing in Growth & Leadership
      • Life at Risk Strategies
      • Next Steps
    • Mergers & Acquisitions
      • Partnership Benefits
      • Why Join Us?
      • Onboarding & Integration
  • Careers
  • Report a Claim
  • Contact Us

You are about to leave Risk Strategies website and view the content of an external website.

You are leaving risk-strategies.com

By accessing this link, you will be leaving Risk Strategies website and entering a website hosted by another party. Please be advised that you will no longer be subject to, or under the protection of, the privacy and security policies of Risk Strategies website. We encourage you to read and evaluate the privacy and security policies of the site you are entering, which may be different than those of Risk Strategies.

OK
  • News and Insights
  • Blog
Subscribe

Subscribe via Email

  • News and Insights
  • Blog
December 12, 2022

Preparing for 2023: Compliance Steps for Group Health Plans

Employee Benefits
4 min read
Erica Honig, J.D., Senior Compliance Director, Employee Benefits
  • Facebook
  • X (Twitter)
  • LinkedIn
  • Email
Preparing for 2023: Compliance Steps for Group Health Plans
  • Facebook
  • X (Twitter)
  • LinkedIn
  • Email

This past year was eventful for group health plan compliance as COVID-related requirements continued in earnest throughout the year and the U.S. Supreme Court Dobbs decision put a spotlight on the coverage of reproductive health services, particularly in certain states. Additionally, the No Surprises Act and other group health plan transparency-related laws and regulations kept plan sponsors and their carriers/third-party administrators busy with various compliance requirements.

These transparency-related requirements are shaping up to be the most significant group health plan-related legislation since the Affordable Care Act (ACA) was signed into law in 2010.

Click here for a look back at the most noteworthy compliance developments for group health plans from 2022.

As we head into the final stretch of the year, employers sponsoring group health plans are advised to take note of and prepare for the following updates and deadlines for early 2023:

New Health Plan Cost-Sharing Tool

The Transparency in Coverage (TiC) Final Rules, finalized in November 2020, required non-grandfathered group health plans to provide a searchable, internet-based self-service tool that reflects accurate cost-sharing and rate information for plan participants. The first phase requires information for 500 specified items and services to be accessible to plan participants by January 1, 2023.

Since plan carriers and third-party administrators (TPA) are in the best position to create and maintain this TiC self-service tool for the first upcoming deadline of January 1, 2023. Click here for more information.

End of HSA Telehealth Relief for 12/31/2022

The CARES Act of 2020 created a temporary safe harbor that permitted Health Savings Account (HSA)-compatible high deductible health plans (HDHP) to cover telehealth and remote care services on a first-dollar basis, or prior to members satisfying their HDHP deductible.

On March 15, 2022, President Biden granted an extension of the temporary safe harbor HSA relief for telehealth services previously provided under the CARES Act of 2020. This temporary relief under the Consolidated Appropriations Act of 2022 is in effect from April 1, 2022, through December 31, 2022. Group health plan sponsors are advised to take note of the upcoming telehealth relief expiration date (December 31, 2022) for their HSA-compatible HDHPs.

UPDATE: On December 23, 2022, new legislation was passed that extends the telehealth relief until December 31, 2024. Please click here to learn more.

Inflation Reduction Act – Insulin Safe Harbor

On August 16, 2022, President Biden signed the “Inflation Reduction Act” (IRA) into law. While the bulk of the IRA is packed with climate and tax-related legislation, the law includes several healthcare-related provisions that could impact prescription drug costs for employer-sponsored group health plans and Medicare Advantage plans in the long run.

A more immediate effect for group health plans is the IRA’s codification of a safe harbor to cover insulin products before individuals covered under a qualified HDHP meet the plan’s deductible. This safe harbor permits HDHPs to provide first-dollar coverage for insulin without jeopardizing an individual’s eligibility to contribute to a Heath Savings Account (HSA) and applies to plan years beginning on or after January 1, 2023.

Many HDHPs are already covering insulin on a pre-deductible basis since current IRS guidance permits insulin and other glucose-lowering agents to be treated as preventive care for individuals diagnosed with diabetes. If your HSA-compatible HDHP does not, take note of this new safe harbor in 2023.

ACA Affordability for 2023

The ACA affordability percentage threshold for plan years beginning January 1, 2023, is set at 9.12%. This change is a significant decrease from the 2022 standard of 9.61% and the lowest this percentage has ever been set since the rules were implemented. As a result, many employers may be required to lower their 2023 employee contribution rates to accommodate this adjusted percentage.

2023 Benefit Plan Limits

Stay informed on benefit plan limits with updated maximum amounts for 2023 when coordinating with benefit administration and payroll vendors. Most, but not all, plan maximum limits have changed from 2022 limits.

Preventive Services Updates

In accordance with the ACA, non-grandfathered group health plans must cover in-network preventive items and services without participant cost-sharing, such as copayments, coinsurance, or deductibles. The list of required preventive items and services is updated on a periodic basis and includes the following updates for 2023 plan years:

  • Obesity prevention counseling for women ages 40 - 60
  • Breastfeeding services and supplies, including breast pumps and breast milk storage supplies
  • Contraception care, including screening, education, counseling, and provision of contraceptives
  • Counseling for sexually transmitted infections
  • Well-woman preventive visits

Group health plan sponsors are advised to update their summary plan descriptions (SPDs) and summaries of benefits and coverage (SBCs) to ensure that coverage of these preventive service updates is provided with no participant cost-sharing.

Planning now and taking action, when necessary, can help set your organization on the right compliance path going into 2023.

Risk Strategies is here to help your organization. Need assistance? Contact us at benefits@risk-strategies.com.

The contents of this article are for general informational purposes only and Risk Strategies Company makes no representation or warranty of any kind, express or implied, regarding the accuracy or completeness of any information contained herein. Any recommendations contained herein are intended to provide insight based on currently available information for consideration and should be vetted against applicable legal and business needs before application to a specific client. 

Related Posts

See all posts

Employee Benefits
10 min read
May 06, 2025

Compliance Reminder: Upcoming PCORI Fee Filing Deadline

Summary: The Patient-Centered Outcomes Research Institute (PCORI) filing and fee payment deadline …
Read article
Employee Benefits
7 min read
May 02, 2025

District Court Ruling Refunds ACA Employer Mandate Penalties and Sets Aside Related Regulation

Summary: In a recent Northern District of Texas court ruling titled “Faulk Company, Inc. v. Xavier …
Read article
Employee Benefits
2 min read
May 01, 2025

IRS Announces Increased HSA, HDHP and EBHRA Limits for 2026

The Internal Revenue Service (IRS) just announced in Revenue Procedure 2025-19 inflation …
Read article
Risk Strategies Logo
  • Report a Claim
  • Contact
  • Terms of Use
  • Cookie Policy
  • Privacy Policy
  • Consumer Health Data Privacy Notice
  • Accessibility
  • Health Plan Transparency Compliance
  • Accessibility
  • Cookie Policy
  • Health Plan Transparency Disclosure
  • Privacy Policy
  • Terms of Use
©2025 Risk Strategies. All rights reserved.

Connect with Us

  • LinkedIn
  • X
  • Instagram
  • Facebook