The Washington Report

December 11, 2024

Holiday Publication Schedule

The Washington Report will be taking a holiday hiatus. Look for your next Washington Report on Wednesday, January 8, 2025. Happy holidays and New Year!

Health

 

HHS Announces Final Regulations on Medicare and Medicaid Programs; Calendar Year 2025 Payment Policies Under the Physician Fee Schedule and Other Changes to Part B Payment and Coverage Policies; Medicare Shared Savings Program Requirements; Medicare Prescription Drug Inflation Rebate Program; and Medicare Overpayments
On November 26, 2024, the Department of Health and Human Services (HHS) released final regulations on Medicare Advantage and Medicare Part D prescription drug proposals. These final regulations address: changes to the physician fee schedule; other changes to Medicare Part B payment policies to ensure that payment systems are updated to reflect changes in medical practice, relative value of services, and changes in the statute; codification of establishment of new policies for the Medicare Prescription Drug Inflation Rebate Program under the Inflation Reduction Act of 2022; updates to the Medicare Diabetes Prevention Program expanded model; payment for dental services inextricably linked to specific covered medical services; updates to drugs and biological products paid under Part B including immunosuppressive drugs and clotting factors; Medicare Shared Savings Program requirements; updates to the Quality Payment Program; Medicare coverage of opioid use disorder services furnished by opioid treatment programs; updates to policies for Rural Health Clinics and Federally Qualified Health Centers; electronic prescribing for controlled substances for a covered Part D drug under a prescription drug plan or a Medicare Advantage Prescription Drug plan under the Substance Use-Disorder Prevention that Promotes Opioid Recovery and Treatment for Patients and Communities Act; update to the Ambulance Fee Schedule regulations; codification of the Inflation Reduction Act and Consolidated Appropriations Act, 2023 provisions; updates to Clinical Laboratory Fee Schedule regulations; updates to the diabetes payment structure and PHE flexibilities; expansion of colorectal cancer screening and Hepatitis B vaccine coverage and payment; establishing payment for drugs covered as additional preventive services; Medicare Parts A and B Overpayment Provisions of the Affordable Care Act and Medicare Parts C and D Overpayment Provisions of the Affordable Care Act. The final regulations become effective on January 1, 2025. 

The news release is available here.

A Fact Sheet is available here.

The final regulations are available here.

IRS Releases Publication 5223 General Rules and Specifications for Affordable Care Act Substitute Forms 1095-A, 1094-B, 1095-B, 1094-C, and 1095-C
On November 25, 2024, the Internal Revenue Service (IRS) released Publication 5223 General Rules and Specifications for Affordable Care Act Substitute Forms 1095-A, 1094-B, 1095-B, 1094-C, and 1095-C. The purpose of this publication is to set forth the tax year 2024 requirements for:

• Using official IRS forms to file information returns with the IRS;
• Preparing acceptable substitutes of the official IRS forms to file information returns with the IRS; and
• Using official or acceptable substitute forms to furnish information to recipients.

IRS Publication 5223 General Rules and Specifications for Affordable Care Act Substitute Forms 1095-A, 1094-B, 1095-B, 1094-C, and 1095-C, is available here.

Retirement

 

DOL, IRS, and PBGC Release Information for Annual Benefits Plan Report/Return Filings
On November 25, 2024, the Department of Labor (DOL), Internal Revenue Service (IRS), and Pension Benefit Guaranty Corporation (PBGC) announced the release of informational copies of the 2024 Form 5500, Form 5500-SF, IRS Form 5500-EZ, IRS Form 5558, and related instructions online. The IRS will release paper copies of Form 5500-EZ and instructions for 2024 separately on its website after January 1, 2025. Each form’s instructions include a Changes to Note section highlighting important updates to the forms, schedules and instructions for 2024, including the following changes in Form 5500 and Form 5500-SF:

• A new plan characteristics code, 2Y, for pension-linked savings accounts.
• An update to Schedule SB instructions for certain expected benefits payable in annuity form.

The news release is available here.

The Form 5500 Series web page is available here.

Retirement

 

2025 Limits for Benefit Plans
Each year, the U.S. government adjusts the limits for retirement plans, Social Security, Medicare, and other benefit programs to reflect price and wage inflation, and changes in the law. As a result, employee benefit plans must be adapted annually to accommodate the new limits. All of the numbers in this report are official unless otherwise indicated. 

The 2025 Limits for Benefit Plans bulletin is available here.