January 2025 Compliance Recap

January brought guidance on the management of taxes on state paid family and medical leave, and an update on the much-watched Johnson & Johnson fiduciary lawsuit. The Department of Health and Human Services provided the 2025 Federal Poverty Levels and FAQs clarify gag clause prohibitions and No Surprises Act compliance relating to downstream contracts. The IRS released Publication 969, providing a reference on compliance for tax-favored accounts. Employers are reminded to file Forms 1094-C and 1095-C and submit the Medicare Part D disclosure. The Department of Labor released inflation-adjusted civil penalties for 2025.

This month's recap includes:

• Court Dismisses ERISA Fiduciary Breach Claims Against Johnson & Johnson
• IRS Issues Tax Guidance on State Paid Family and Medical Leave Programs
• HHS Updates 2025 Federal Poverty Levels and ACA Affordability Impact
• FAQs Clarify Gag Clause Prohibitions and No Surprises Act Compliance
• IRS Publication 969 Outlines Compliance for Tax-Favored Health Plans
• Employer Reporting Requirements for Forms 1094-C and 1095-C
• Prepare to File Medicare Part D Disclosure to CMS
• 2025 Adjustments to DOL Penalties
• Question of the Month

Continue reading the full January compliance recap.

_{SOURCE: United Benefit Advisors (UBA). This information is general and provided for educational purposes only by United Benefit Advisors (UBA) for UBA Partner Firm member distribution. It reflects UBA’s understanding of the available guidance as of the date shown and is subject to change. It is not intended to provide legal advice.  You should not act on this information without consulting legal counsel or other knowledgeable advisors.}