Keeping track of compliance deadlines is essential for employers to avoid penalties and ensure smooth operations. This compliance calendar highlights critical dates and the actions required to maintain compliance with federal regulations. Below is an overview of important deadlines, along with detailed explanations to guide you through the requirements.
January 31
Form W-2 Reporting
- What to do:
- Provide Form W-2 to employees.
- Include:
- Aggregate cost of employer-sponsored group health coverage (box 12, code “DD”).
- Imputed income from benefits (e.g., non-dependent domestic partner coverage).
- Contributions to Health Savings Accounts (box 12, code “W”).
- Why it matters: Accurate reporting ensures employees receive correct tax documentation and reduces the risk of penalties for employers.
March Deadlines
March 3: Annual Notice of Creditable Coverage
- What to do: Submit this notice online to the Centers for Medicare & Medicaid Services (CMS) within 60 days of the plan year’s start.
- Additional Resources: CMS Disclosure Form.
March 31: IRS Form 1094/95 Electronic Filing
- What to do:
- File IRS Forms 1094-B/C and 1095-B/C for the prior year’s health coverage.
- Employers with 10 or more forms must file electronically.
- Why it matters: Timely filing ensures compliance with ACA reporting obligations.
June 30: Prescription Drug Reporting
- What to do:
- Group health plans must report prescription drug and healthcare spending data to HHS, Labor, and Treasury.
- Work closely with carriers or third-party administrators to meet these requirements.
- What’s included: Data on plan coverage, spending, and rebates received.
July Deadlines
July 31: Form 5500 Filing
- What to do: File Form 5500 for ERISA plans or request an extension (Form 5558).
- Who it applies to: Plans with 100+ participants or those not exempt.
- Additional Resources: Form 5500 Filing Instructions.
July 31: ACA PCORI Fee
- What to do: Pay the Patient-Centered Outcomes Research Institute fee for the prior year.
- Why it matters: This fee supports research to improve healthcare decision-making.
September 30: Summary Annual Reports (SARs)
- What to do: Distribute SARs to eligible participants within nine months after the plan year ends.
October Deadlines
October 15: Creditable Coverage Notices
- What to do: Provide notices to employees about whether the group plan offers creditable prescription drug coverage.
- Why it matters: Ensures employees make informed Medicare Part D enrollment decisions and avoid penalties.
December Deadlines
December 15: Summary Annual Report (if Form 5500 Extension Filed)
- What to do: Distribute SARs if you filed for an extension earlier in the year.
December 31
Women’s Health and Cancer Rights Act Notice
- What to do: Provide this annual notice to plan participants and beneficiaries.
Children’s Health Insurance Program (CHIP) Notice
- What to do: Send CHIP notices to employees about premium assistance opportunities.
- Additional Resources: Model CHIP Notice.
Gag Clause Compliance Attestation
- What to do: Submit the attestation required under the CAA (Consolidated Appropriations Act).
Less Common Deadlines
- January 1: Distribute ACA Grandfather Status Notices (if applicable).
- October 1: Provide Individual Coverage HRA Notices (for ICHRAs).
Event-Based Deadlines
Summary Plan Description Issuance
- What to do: Provide ACA Notices (Primary Care Provider Designation & OB-GYN Care).
- Additional Requirements: Include HIPAA Wellness Notice if applicable. This applies to plans with primary care designations or wellness programs offering rewards/penalties.
Wellness Program Description
- What to do: Distribute HIPAA Wellness Notice for programs with rewards tied to health factors or activities.
HIPAA Anniversary
- What to do: Remind participants of the availability of the HIPAA Privacy Notice every three years.
Explanation of Benefits Issuance
- What to do: Distribute “Surprise” Billing Protections Notice under the No Surprises Act.
MEWA-Specific Deadlines
- What to do: File Form M-1 before operating in a new state or within 30 days of certain events like mergers or employee increases.
Enrollment or Hiring Deadlines
New Employee Hiring
- What to do:
- Provide Notice of Exchange within 14 days of hire.
- Distribute HIPAA Special Enrollment Notice before enrollment.
Enrollment Process
- What to include:
- Summary of Benefits and Coverage (SBC).
- Initial Social Security/Taxpayer ID solicitation for ACA reporting.
- HIPAA Privacy Notice.
- Women’s Health and Cancer Rights Act Notice.
Wellness Program Participation
- What to do: Provide EEOC Wellness Notice for programs requiring medical examinations or health questionnaires.
Post-Enrollment
- What to do:
- Provide COBRA General Notice within 90 days of enrollment.
- Distribute HIPAA SBCs for special enrollment within 90 days.
Plan Changes
Material Changes to Benefits
- What to do:
- Provide updated SBC at least 60 days before changes.
- Issue Summary of Material Modifications (SMM) within 60 days of reducing benefits.
Annual Deadlines
Social Security/Taxpayer ID Follow-Up
- What to do: Conduct second follow-up for Social Security/Taxpayer IDs by December 31 if not obtained.
Resources and Model Notices
Most notices have templates provided by the Department of Labor (DOL) or other agencies. Links to model notices are available for most compliance documents.
Why Staying Compliant Matters
Compliance ensures your organization meets legal requirements, avoids penalties, and maintains trust with employees and regulators. Use this calendar to stay on top of your responsibilities and ensure your team is prepared for upcoming deadlines.
For further information, consult the relevant government resources linked throughout this guide.
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