🗓️ November 2024
Keeping HR pros updated with important compliance, benefits, and human resources information.
Judge Strikes Down Overtime Rule Nationwide;
Salary Threshold for Exempt Employees Now $684/week
A federal court has struck down the Biden administration’s overtime rule, reverting the minimum salary threshold for the “white-collar” exemptions under federal overtime requirements to $684 per week ($35,568 annually) nationwide. This decision also halts the planned increase to $1,128 per week, which was set to take effect on January 1.
The court ruled that the U.S. Department of Labor exceeded its authority under the Fair Labor Standards Act. Specifically, the judge stated that a minimum salary level is permissible only if it reasonably reflects an employee’s exemption status. The court found that the sharp increases outlined in the rule did not meet this standard and instead improperly replaced the statutory duties test with a non-statutory salary-level requirement.
We’ll continue monitoring this situation closely to see if the government appeals the decision and will share updates as they become available. If you have any questions, feel free to reach out—we’re here to help!
IRS Releases 2025 Benefit Plan Limits
Recent IRS cost-of-living adjustments will affect key benefit programs for 2025. Understanding and implementing these changes can help optimize tax advantages, maintain compliance, and support employees in managing their healthcare and other related costs.
| Health Flexible Spending Accounts (FSAs) | 2024 | 2025 |
| Maximum salary reduction contribution | $3,200 | $3,300 |
| Maximum carryover amount to the next plan year | $640 | $660 |
| Transportation Fringe Benefits | 2024 | 2025 |
| Monthly parking benefit exclusion | $315 | $325 |
| Monthly transit and vanpooling limit | $315 | $325 |
| Dependent Care Assistance Program (DCAP) | 2024 | 2025 |
| Maximum benefit – single/married, filing separately | $2,500 | $2,500 |
| Maximum benefit – married, filing jointly | $5,000 | $5,000 |
| Qualified Small Employer Health Reimbursement Arrangements (QSEHRAs) | 2024 | 2025 |
| Maximum for self-only coverage | $6,150 | $6,350 |
| Maximum for family coverage | $12,450 | $12,800 |
| Health Savings Accounts | 2024 | 2025 | ||
| Self-only | Family | Self-only | Family | |
| Contribution limit | $4,150 | $8,300 | $4,300 | $8,550 |
| Minimum deductible | $1,600 | $3,200 | $1,650 | $3,330 |
| Out-of-pocket expense limit | $8,050 | $16,100 | $8,300 | $16,600 |
| Catch-up contribution if 55 or older | $1,000 | $1,000 | ||
Employer Considerations
- Update all benefits documents to reflect 2025 limits.
- Work with payroll and benefits vendors to implement new contribution and reimbursement caps.
- Communicate the 2025 limits to employees during open enrollment, highlighting potential impacts.
- Brief HR teams on new limits to ensure accurate administration and employee support.
New HIPAA Rules Require Immediate Action by Employers
Following the Supreme Court’s overturning of Roe v. Wade, the Office of Civil Rights (OCR) within the Department of Health and Human Services (HHS)—the agency responsible for enforcing HIPAA—has issued new guidance to strengthen the protection of Protected Health Information (PHI) related to reproductive health care.
Immediate Action Required
Employers who are Covered Entities (e.g., health plans) and Business Associates need to act now. By December 23, 2024, you must:
- Train relevant workforce members.
- Update HIPAA policies and procedures to align with the new guidance.
Additionally, you will need to revise your Notice of Privacy Practices (NPP), though the deadline for the updated NPP is February 16, 2026.
Key Details
Under the new guidance, Covered Entities and Business Associates are prohibited from using or disclosing PHI related to reproductive health care for:
- Criminal, civil, or administrative investigations,
- The imposition of liability, or
- Identifying a person for any of these purposes.
If a Covered Entity or Business Associate receives a request for PHI potentially tied to reproductive health care for activities such as:
- Health oversight,
- Judicial or administrative proceedings,
- Law enforcement, or
- Coroners or medical examiners (for decedents),
The requestor must provide a written attestation confirming that the PHI will not be used for any prohibited purpose. The attestation must meet specific content and format requirements outlined in the guidance.
We recommend reviewing this new guidance immediately to ensure compliance and avoid potential penalties. Let us know if you have questions or need assistance navigating these updates.
Question of the Month
Q. How long should an employer keep insurance benefits proposals and quotes?
A. ERISA has a six-year statute of limitations. Therefore, it’s prudent to keep insurance quotes and proposals for at least six years to justify decisions made by the company within ERISA’s statute of limitations.
