Filing is due for ERISA plans, unless exempt. Filing is made electronically with the DOL at: www.efast.dol.gov. Welfare plans that are fully insured, unfunded or a combination of both are excused from filing if they have fewer than 100 participants as of the first day of the ERISA plan year. Consider the need to file […]
Patient-centered Outcomes Research Trust Fund Fee must be paid by issuers of specified health insurance policies and plan sponsors of applicable self-insured health plans (including HRAs). Payment is due annually, by July 31, of the calendar year following the end of the plan year. For more information, see: https://www.irs.gov/newsroom/patient-centered-outcomes-research-institute-fee
Distribute to participants, COBRA beneficiaries and alternate recipients under QMCSOs within 9 months after close of the plan year or 2 months after the plan's extended 5500 deadline. SAR requirement does not apply to plans that pay benefits exclusively from the employer's general assets (that is, plans with no trust, with no insurance contract to […]
Only applies to employers that sponsor individual coverage health reimbursement arrangements (ICHRAs) Due at least 90 days before the beginning of the plan year. Notice must include specific information about the ICHRA, including the maximum dollar amount, some limitations of the ICHRA, a statement of the right to opt-out, and the effect on the individual’s […]
Provide to employees, retirees and dependents enrolled in or eligible for Medicare and also enrolled (or seeking enrollment) in the employer's group plan. The Notices are good for the next 12 months after they are distributed (e.g., if distributed in enrollment packets during prior year), unless the coverage changes from creditable to non-creditable (or from […]
If Form 5558 was submitted to the IRS seeking an extension of the deadline to submit Form 5500, filing of Form 5500 is now required. Does not apply to governmental plans (state and local). Does not apply to church plans that have not elected to be covered by ERISA.
ACA Exchange open enrollment generally begins November 1.
If an extension was filed for Form 5500, a Summary Annual Report needs to be distributed to employees at this time. Does not apply to governmental plans (state and local). Does not apply to church plans that have not elected to be covered by ERISA.
The WHCRA notice is distributed at initial enrollment, and then annually, prior to each plan year, to participants (and to beneficiaries whose last-known address is different from the last-known address of the participant). A model notice and other information can be found at: https://www.dol.gov/sites/default/files/ebsa/about-ebsa/our-activities/resource-center/publications/compliance-assistance-guide.pdf Note that a separate, more detailed notice must be distributed after […]
The CHIP notice must be provided before the first day of the plan year. The CHIP notice must be separate, but may be provided with other open enrollment materials or the SPD. Separate mailing is not required. Electronic distribution is permitted if meeting the DOL safe harbor requirements. A model notice (called “Model Notice for […]
The Gag Clause Prohibition Compliance Attestation must be submitted annually to the Departments of Labor, Health & Human Services, and the Treasury by December 31 of each year. More information at: https://www.cms.gov/marketplace/about/oversight/other-insurance-protections/gag-clause-prohibition-compliance-attestation#:~:text=A%20Gag%20Clause%20Prohibition%20Compliance,of%20the%20plan%20or%20coverage
Only applies to self-funded governmental (state and local) health plans. Opt-out available for Mental Health Parity Act, Newborns and Mothers Health Protection Act, Women's Health and Cancer Rights Act, and Michelle's Law. The plan must provide notice of the opt-out to participants at the time of enrollment and on an annual basis, prior to the […]
