Compliance & Policy

Legal/Compliance Roundup - June 2024

UPDATED ON
June 3, 2024
Jamie Polen
Jamie Polen
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Each month, Mployer Advisor collects and presents some of the most relevant and most pressing recent changes in law, compliance, and policy in areas related to employee benefits, health care, and human resources. 

2023 EEO-1 Component 1 Submissions Due Date Set

Final deadline for EEO-1 Component 1 submissions is for June 4, 2024.

Check the Equal Opportunity Employment Commission (EEOC) website for updates as well as an instruction booklet and file submission specifications.

This filing must be submitted by every company that has 100 or more employees across all locations and/or is affiliated with a company that has 100 or more employees through common ownership or centralized management. 

Further, this filing must also be submitted by any company with 50 employees or more that has a contract with the federal government worth at least $50,000 or has an establishment that holds a federal contract worth at least $50,000. 

Companies or establishments thereof that are federal contractors and serve as depositories of federal funds no matter how much or how little, as well as financial entities that are issuing and paying agents for US Savings Bonds and Savings notes must also submit this form. 

Updates regarding the timely, etc. will be posted here on the EEO-1 website.

Overtime/Minimum Wage Exemption Threshold Increases

The Department of Labor recently increased the pay thresholds for Executive, Administrative, and Professional employees (EAP) including salaried computer workers, and Highly Compensated Employees (HCEs) to remain exempt from federal minimum wage and overtime laws.

Beginning on July 1, 2024 the EAP exemption threshold will increase from $35,568 to $43,888. That threshold number is also set to rise again the following year on January 1, 2025, when the EAP exemption minimum annual salary rises to $58,656, after which automatic increases will begin July 1, 2027 and every three years after that. 

The increase in the minimum HEC exemption threshold follows a similar path, increasing first on July 1, 2024 up to $132,964, before increasing again to $151,164 on January 1, 2025 and every three years after beginning on July 1, 2027. 

The overtime and minimum wage exemption threshold for computer workers that are paid hourly remains at $27.63 per hour, while the threshold for computer workers paid on salaried basis is linked with the EAP minimum. 

Barring any unforeseen changes or court-initiated interventions, the first exemption-threshold increases are set to take effect in one  month. 

In preparation, employers and human resources professionals may want to identify all the employees who may be affected and assess whether to increase their pay in accordance with the rate increases or whether it is better to begin paying them overtime (and minimum wage if applicable) instead. 

You can find more about these exemption threshold increases here

HSA & HDHP Inflation Adjustments Announced

The IRS announced the 2025 adjustments to health savings account and high deductible health plans:

The self-coverage limit increased by $150 to $43,00 while the family coverage limit increased by $250 to $8,550.

There was a $50 dollar increase on the minimum annual HDHP deductible, bringing it up to $1,650, while the family coverage deductible rose by $100 up to $3,300. 

The maximum yearly out-of-pocket expenses for single coverage HDHPs -including premiums, deductibles, and other related expenses - rose by $250, climbing up to $8,300, while the family coverage equivalent increased by $500, up to $16,600.

You can read more about those adjustments here

Federal Prescription Data Reporting Updates

RxDC reports for calendar year 2023 are due June 3, 2024.

This information is usually submitted by carriers, pharmacy benefits managers, and third party admins - although these entities may need to seek out final information directly from employers prior to the deadline.

Some of the noteworthy updates to this year’s submission instructions include:

  • Clarification that nutritional supplements, over-the-counter medication, and medical devices are not to be included on lists of prescription drugs;
  • Simplification of the total monthly premium calculation, now computed by dividing the total annual premium by twelve;
  • Simplification of premiums calculation accounting for paid claims instead of incurred claims;
  • Addition of a new column to input enrollment data; and
  • Instructions on how to submit large data files that exceed the maximum allowable limit, as well as updated instructions on how to input various other data;

Click here for the Centers for Medicare and Medicaid Services 2023 instruction guide for RxDC submissions.

Pregnant Workers Fairness Act

The final regulations in support of the Pregnant Workers Fairness Act (PWFA) have been published and go into effect on June 18, 2024.

Some of the accommodations that the final rule presumes to be reasonable absent an especially significant justification for denying the accommodation, including allowing pregnant employees to: 

  • Take breaks to eat and drink;
  • Keep water nearby;
  • Use the restroom as needed; and
  • Sit or stand as needed

The rule also places a number of limitations for when employers can require supporting documentation in order for employees to request or receive accommodations under the rule, allowing employers to request such documentation only when it is reasonable under the circumstances.

The final rule also requires accommodations for medical appointments, and defines certain terms broadly enough to require accommodations for medical care involving fertility, contraception, and situations when pregnancies abruptly end whether willfully or not. 

You can find the final rule here.

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