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group health plans 2022

2022 Compliance Calendar for Group Health Plans

January 31

Deadline for providing Form W-2 to employees and filing of W-2 forms (and W-3 transmittal) with the Social Security Administration. 

  • Unless future guidance changes the applicability of this requirement, employers who filed at least 250 Forms W-2 for the 2020 year must report the aggregate value of applicable employer-sponsored health coverage on the 2021 Forms W-2. 

February 28 

Deadline for paper filers to provide Form 1094-C (or Forms 1094-B, if applicable) to the IRS. 

  • Applicable large employers and sponsors of self-insured health plans must use Form 1094-C to file copies of Forms 1095-C with the IRS (or Form 1094-B to submit Forms 1095-B, if applicable). The filing deadline is the last day of February following the end of the reporting year for filers filing with paper or March 31, following the end of the reporting year for filers filing electronically. 
  • An automatic 30-day extension is available if Form 8809 is filed by this due date. The extension applies only to IRS filings, not to the distribution of Forms 1095-C/1095-B to individuals. 
  • Instructions are available at https://www.irs.gov/uac/about-form-1094-c and https://www.irs.gov/uac/about-form-1094-b 

February 28 

Form 8809, Application for Extension of Time To File Information Returns (for paper filers).

March 1

Creditable Coverage Disclosure due to CMS. 

March 2

Deadline for providing 2022 Forms 1095-C (or Forms 1095-B, if applicable) to individuals. 

March 31

Due date for Forms 1094-C/1094-B to be filed with the IRS (if extended)

 (For paper filers) 

  • Applicable large employers and sponsors of self-insured health plans must use Form 1094-C to file copies of Forms 1095-C with the IRS (or Form 1094-B to submit Forms 1095-B, if applicable). The filing deadline is the last day of February, following the end of the reporting year for filers filing with paper or March 31, following the end of the reporting year for filers filing electronically. When the filing deadline falls on a weekend, the due date is the next business day. 
  • An automatic 30-day extension is available if Form 8809 is filed by this due date. The extension applies only to IRS filings, not to the distribution of Forms 1095-C/1095-B to individuals. 
  • Instructions are available at https://www.irs.gov/uac/about-form-1094-c and https://www.irs.gov/uac/about-form-1094-b

April 1 

Deadline for electronic filers to provide Form 1094-C (or Forms 1094-B, if applicable) to the IRS 

  • Applicable large employers and sponsors of self-insured health plans must use Form 1094-C to file copies of Forms 1095-C with the IRS (or Form 1094-B to submit Forms 1095-B, if applicable). The filing deadline is the last day of February following the end of the reporting year for filers filing with paper or March 31, following the end of the reporting year for filers filing electronically. When the filing deadline falls on a weekend, the due date is the next business day. 
  • An automatic 30-day extension is available if Form 8809 is filed by this due date. The extension applies only to IRS filings, not to the distribution of Forms 1095-C/1095-B to individuals. 
  • Instructions are available at https://www.irs.gov/uac/about-form-1094-c and https://www.irs.gov/uac/about-form-1094-b  

April 2

Form 8809, Application for Extension of Time To File Information Returns (for electronic filers) 

May 2 

Due date for Forms 1094-C/1094-B to be filed with the IRS (if extended) (For electronic filers) 

  • Applicable large employers and sponsors of self-insured health plans must use Form 1094-C to file copies of Forms 1095-C with the IRS (or Form 1094-B to submit Forms 1095-B if applicable). The filing deadline is the last day of February, following the end of the reporting year for filers filing with paper or March 31, following the end of the reporting year for filers filing electronically. 
  • An automatic 30-day extension is available if Form 8809 is filed by this due date. The extension applies only to IRS filings, not to the distribution of Forms 1095-C/1095-B to individuals. 
  • Instructions are available at https://www.irs.gov/uac/about-form-1094-c and https://www.irs.gov/uac/about-form-1094-b 

July 30 

Summary of Material Modifications due to participants 

  • If there has been a material amendment, due no later than 210 days after the end of the plan year in which the plan change is adopted. New participants must receive within 90 days of becoming a plan participant. When the distribution deadline falls on a weekend, the due date is the next business day. 
  • Important Note: If a modification or change to a group health plan produces a material reduction in covered services or benefits under the plan, different deadlines apply. See the section below on deadlines that are not calendar-specific for more information. 

July 31 

Form 5500 is due (unless extended) 

July 31 

Form 5558 Application for Extension of Time to File Certain Employee Plan Returns is due 

July 31

Patient Centered Outcomes Research Institute (“PCORI”) fee due date 

September 17 

Form 5500 due (if relying on automatic extension based on the extension of federal corporate income tax return due date) 

  • Due the last day of the seventh month after the plan year-end, unless an extension is requested or automatically provided based on extension of the federal corporate income tax return. An automatic extension applies until the extended due date for the federal corporate income tax return if (1) the plan year and the employer’s tax year are the same; (2) the employer has been granted an extension of time to file its federal income tax return to a date later than the normal due date for filing the Form 5500; and (3) a copy of the application for extension of time to file the federal income tax return is maintained with the filer’s records. 

October 1 

Summary Annual Report due to participants (if 5500 deadline not extended) 

  • Due to participants nine months after the plan year-end or two months after the extended due date for filing the Form 5500. When the distribution deadline falls on a weekend, the due date is the next business day. 

October 3 

QSEHRA notice due to eligible employees 

  • Employers that offer a qualified small employer health reimbursement arrangement in lieu of health coverage for a year must provide a notice to eligible employees at least 90 days before the beginning of the year. 

October 14

Medicare Part D Notice of Creditable Coverage due to participants 

  • Notice must be provided (1) before October 15 of each year, (2) prior to an individual’s initial enrollment period for Part D, (3) prior to the effective date of coverage for any Part D eligible individual who enrolls in the plan’s prescription drug coverage, (4) when the plan no longer provides any drug coverage or when the coverage is no longer creditable, and (5) upon request. 
  • Information regarding creditable coverage and model notices can be found at: http://www.cms.hhs.gov/CreditableCoverage/01_Overview.asp 

October 15

Form 5500 due (if extended by filing a Form 5558) 

November 15 

Summary Annual Report due to participants (if 5500 deadline extended via automatic extension) 

  • Due to participants nine months after the plan year-end or two months after the extended due date for filing the Form 5500. 

December 17 

Summary Annual Report due to participants (if 5500 deadline extended via submission of Form 5558) 

  • Due to participants nine months after the plan year-end or two months after the extended due date for filing the Form 5500. When the distribution deadline falls on a weekend, the due date is the next business day. 

Annually 

Women’s Health and Cancer Rights Act notices 

Annually 

CHIP premium assistance notices 

Additional Notes

HIPAA notice of privacy practices for protected health information 

  • Every three years, a plan must either provide its Notice of Privacy Practices to participants or notify participants that a Notice of Privacy Practices is available. 
  • In addition, the notice must be given upon enrollment and upon request. When there is a material change to the notice, an updated notice must be posted to the benefits website by the effective date of the change and distributed with the next annual mailing to participants. If the employer does not maintain a benefits website, the updated notice must be distributed within 60 days of the effective date of the change. 
  • A model notice can be found at: http://www.hhs.gov/ocr/privacy/hipaa/modelnotices.html 

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