2024 Affordable Care Act Compliance Checklist

The Affordable Care Act (ACA) made a number of reforms to group health plan coverage when it was enacted in 2010. Since then, changes have been made to various ACA requirements that employers should be aware of. These changes include annual cost-of-living increases to certain ACA dollar limits, extensions to ACA reporting deadlines and updates to preventive care coverage guidelines.

Changes to some ACA requirements will take effect in 2024 for employers sponsoring group health plans. Significantly, the affordability percentage under the ACA’s employer mandate rules for applicable large employers (ALEs) will be at its lowest point for plan years beginning in 2024, which may require many ALEs to lower their employee contribution rates.

To prepare for 2024, employers should review these ACA requirements and develop a compliance strategy. Employers should ensure that their health plan documents, including the summary of benefits and coverage (SBC), are updated to reflect any new plan limits and that up-to-date information is communicated to employees at open enrollment time.

PLAN DESIGN CHANGES

The following plan design requirements have changed for 2024:

• Limits on cost sharing for essential health benefits
• Coverage affordability percentage under the employer mandate rules
• Dollar amounts for calculating penalties under the employer mandate rules

REPORTING DEADLINES

The following deadlines apply for reporting under Sections 6055 and 6056:

• April 1, 2024: Electronic IRS returns for 2023 must be filed by this date.
• March 1, 2024: Individual statements for 2023 must be furnished by this date.
• Feb. 28, 2024: Paper IRS returns for 2023 are due by this date.

​LINKS & RESOURCES

• IRS Rev. Proc. 2023-29 indexed the ACA’s affordability contribution percentage for 2024.
• IRS Rev. Proc. 2023-17 increased the penalty amounts under the ACA’s employer mandate for 2024.
• CMS guidance established the cost-sharing limits for 2024.