Intro: Why Mid-Year Matters
Compliance isn’t just a December checklist. It’s an ongoing process. As regulations evolve and benefit offerings shift, a mid-year audit can be your best defense against penalties, plan disruption, and legal exposure.
For self-funded and public sector employers, this check-up is a chance to course-correct early and strengthen your HR and finance teams’ confidence heading into Q4.
1. ERISA Plan Documents: Are Yours Up to Date?
– Ensure your Summary Plan Description (SPD) is current
– Confirm all benefits are covered by a wrap document
– Match what’s legally promised with what’s being communicated
Recent changes like mental health, virtual care, or lifestyle stipends may require updates to your documentation – even if no plan design changes occurred. Plan documents form the legal foundation of your benefits offering…
The Department of Labor outlines these requirements clearly in this detailed guide for plan sponsors.
2. ACA Compliance: The Clock is Always Ticking
– Accurate 1095-C tracking based on your measurement methods
– Contribution tiers that meet the IRS affordability threshold
– Proper safe harbor strategy for your employee population
And don’t forget state-specific mandates – some states have new individual mandate reporting in effect for 2025.
3. COBRA & HIPAA: The Overlooked Risks
– Your COBRA notice delivery and timing
– Any HIPAA privacy training gaps (especially with new staff)
– BAA documentation for all third-party vendors
Recent layoffs or restructuring? COBRA compliance should be a top priority.
4. Mental Health Parity: The CAA Changed the Game
– Prior authorization
– Provider access and reimbursement
– Step therapy and treatment limits
Many employers are still catching up here. Audits are increasing. Work with your TPA to prepare the required NQTL analysis. Review our breakdown of employer responsibilities under the CAA for more detailed guidance.
5. Notices and Communications: Are You Covered?
– Required notices are distributed and acknowledged (SBCs, HIPAA, CHIPRA, WHCRA, etc.)
– Open enrollment materials are up-to-date and legally clear
– Electronic delivery methods are DOL-compliant
Most errors come from poor documentation. Get ahead of it now.
6. Vendor Oversight: Trust But Verify
– Transparency rule reporting compliance (machine-readable files, cost estimators)
– Updated certifications or contracts from your broker, PBM, and TPA
– Active BAAs for any vendor accessing protected health information
MSI can help evaluate vendors and benchmark them against industry best practices. Leverage your audit findings to improve plan performance – here’s how data and analytics help.
7. Preparing for 2025 Compliance Trends
– Medicare Part D out-of-pocket cap: $2,000 limit begins 2025
– Preventive services clarity for HDHPs under IRS rules
– More CAA reporting obligations around pharmacy costs and broker fees
Let’s Schedule Your Mid-Year Review
Mid-year audits can uncover gaps, improve vendor alignment, and help you avoid unpleasant surprises during renewal.
Let MSI Benefits Group guide your mid-year compliance review. Our expert consultants will walk you through plan documents, vendor contracts, notices, and strategic readiness for 2025.
👉 Contact us now to discuss an audit or call us directly at (770) 425-1231.