Employee Benefit Broker & Health Insurance Agency in NJ

Self-Funded State and Local Government Health Plans Submit Optional Opt-Out Election to CMS
2025-12-31 | Cosmo Insurance, NJ, United States
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
beginning of each plan year. A model notice can be found at:
https://www.cms.gov/CCIIO/Resources/Files/hipaa_exemption_election_instructions_04072011
.html

Distribute Gag Clause Attestation Notice
2025-12-31 | Cosmo Insurance, NJ, United States
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

Distribute Children’s Health Insurance Premium Assistance Notice
2025-12-31 | Cosmo Insurance, NJ, United States
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 Employers Regarding Premium Assistance Opportunities”) can be found at: https://www.dol.gov/agencies/ebsa/employers-and-advisers/plan-administration-and-compliance/health-plans

Distribute Annual Women's Health and Cancer Rights Act Notice
2025-12-31 | Cosmo Insurance, NJ, United States
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 enrollment (see “Deadlines Based on When Events Happen” below).

Distribute Summary Annual Report, if Extension was Filed.
2025-12-15 | Cosmo Insurance, NJ, United States
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.

Open Enrollment for the ACA Exchanges Begins
2025-11-01 | Cosmo Insurance, NJ, United States
ACA Exchange open enrollment generally begins November 1.

Form 5500 For Prior Plan Year, if Extension was Filed
2025-10-15 | Cosmo Insurance, NJ, United States
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.

Distribute Notices of Creditable and/or Non- Creditable Coverage
2025-10-15 | Cosmo Insurance, NJ, United States
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 non-creditable to creditable). Model notices may be found at: https://www.cms.gov/Medicare/Prescription-Drug- Coverage/CreditableCoverage/Model-Notice-Letters.html
Individuals are generally required to enroll in Medicare Part D prescription drug coverage when
they first become eligible and may be subject to late enrollment penalties if they fail obtain
creditable prescription drug coverage for 63 consecutive days or longer. Each year employers
are required to address Medicare Part D prescription drug coverage in two ways:

By completing an online filing with CMS within the first 60 days of each plan year
certifying whether the employer provides prescription drug creditable coverage.
By providing the employees with a notice before October 15th informing them of whether the
prescription coverage is creditable.

Distribute annual Individual Coverage HRA Notice (if applicable)
2025-10-01
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 ability to obtain
premium tax credits for individual coverage, among other items.
A model notice is available here: https://www.irs.gov/pub/irsutl/health_reimbursement_arrangements_faqs.pdf

Distribute Summary Annual Reports (SARs)
2025-09-30
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 pay benefits, where participant
contributions are made through a Section 125 plan, etc.).

Does not apply to governmental plans (state and local). Does not apply to church
plans that have not elected to be covered by ERISA.

Deadline for Filing Form 720 and Payment of ACA PCORI Fee for prior Plan Year
2025-07-31
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

File Form 5500 for Prior Plan Year (or File Form 5558 to Request 2 1⁄2 Month Extension)
2025-07-31
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 for health FSAs and other programs often overlooked, such as
severance pay plans, EAPs, and some voluntary coverage.
For more information, see: https://www.dol.gov/agencies/ebsa/employers-and-advisers/plan-administration-and-compliance/reporting-and-filing/form-5500
The deadline is July 31.
Does not apply to governmental plans (state and local). Does not apply to church plans that have not elected to be covered by ERISA.

Prescription Drug Reporting
2025-06-02
Group health plans must report on certain prescription drug information to HHS, Labor, and Treasury.
Reporting must include information regarding plan coverage and premiums, as well as the
amount spent, and increase in spend, on various prescription drugs. Total spending on health
care services is also included. The report must also disclose the impact on premiums of any
rebates received from drug manufacturers.
Rules are still being developed. Employers should work with their carriers or administrative
services only providers/third party administrators to facilitate reporting.

IRS Form 1094/95 – B & C electronic filing due
2025-03-31
Applicable large employers and others furnishing 10 forms or more must file all Forms 1095 – B/C with the IRS.
If filing Form 8809, deadline for filing with the IRS extends out 30 days. For more information, see: https://www.irs.gov/forms-pubs/form-8809-application-for-extension-of-time-to-file-
information-returns

Last Day of 2 1⁄2 Month Grace Period for Flexible Spending Accounts with Grace Periods
2025-03-15
Only applies to employers who offer an FSA plan with a 2 1⁄2 month grace period. Employees
may no longer incur expenses that can be paid for with contributions from the immediately
preceding FSA plan year. Note that a plan could have an earlier deadline.

File Form M-1 (Annual Report) on behalf of Multiple Employer Welfare Arrangements (MEWAs) Providing Health Coverage
2025-03-03
Only applies to a health plan or other arrangement that covers employees of two or
more companies that have less than 25 percent common ownership interest at any time
during the plan year (including most association health plans).
For established MEWAs, Form M-1 (Annual Report) must be filed by March 1 each year.
Some exceptions to the initial filing date apply. For more information, see: https://www.dol.gov/agencies/ebsa/laws-and-regulations/laws/affordable-care-act/for-employers-and-advisers/mewas

Deadline for providing Forms 1095-B/C to Employees
2025-03-03
Applicable Large Employers (i.e. those that are subject to the employer mandate) must report
on the coverage offerings for each ‘full-time employee’ from the previous calendar year.
Self-funded employers (of any size) are required to report on coverage provided to any
employee in the prior calendar year.
For more information, see: https://www.irs.gov/uac/About-Form-1095-B and
https://www.irs.gov/forms-pubs/about-form-1095-c

IRS Form 1094/95 – B & C paper filing due- February 28 deadline for 2025
2025-03-03
Every person that provides minimum essential coverage to an individual during a calendar
year must file an information return reporting the coverage. Insurers generally use Form 1094-
B (transmittal) to submit Forms 1095-B (returns) to the IRS. However, self-funded employers
(including governmental employers) subject to the employer shared responsibility provisions
generally will report information about the coverage in Part III of Form 1095-C instead. For
more information, see: https://www.irs.gov/uac/About-Form-1095-B and
https://www.irs.gov/forms-pubs/about-form-1095-c
Only employers furnishing fewer than 10 forms are permitted to file by paper; all others must
file electronically.

Submit Annual Notice of Creditable and/or Non-Creditable Coverage to CMS
2025-03-03
Notice is required within the first 60 days of the plan year. Filing is made online at: https://www.cms.gov/Medicare/Prescription-Drug-Coverage/CreditableCoverage/CCDisclosureForm.html

More detail on creditable/non-creditable coverage is included in the discussion of the notices
to participants by October 15.

Reporting health plan costs on Form W-2 Deadline
2025-01-31
Employers that filed 250 or more IRS Forms W-2 for the prior calendar year must include the aggregate cost of employer-sponsored health plan coverage on employees’ Forms W-2. This reporting is optional for employers that had to file fewer than 250 Forms W-2 for the prior calendar year. Employers must file Forms W-2 with the Social Security Administration and furnish Forms W-2 to employees by Jan. 31 of each year unless an extension applies.

Quarterly Report Deadline
2025-01-31
For the 4th quarter of the previous calendar year.

Horizon Conversion Deadline For The Upcoming 1st Of The Month
2025-01-20

Horizon Enrollment Deadline For 15th Of The Month
2025-01-14

TiC: Machine- Readable Files
2025-01-01
Employers with Self-funded/Level-Funded health plans
Plan is ultimately responsible for updating three machine readable files (MRFs) disclosing: in-network rates, OON allowed amounts, billed charges, negotiated rates and historical net prices for Rx drugs.
Employers should collaborate with a third-party administrator to ensure the plan is administered in accordance with the TiC rules at each renewal.
Subject to $100 per day per participant for non-compliance.

Section 105(h) Nondiscrimination Testing
2025-01-01
Employers with Self-funded/Level-Funded health plans
This rule prohibits group health plans from discriminating in favor of highly compensated individuals with respect to both eligibility and benefits offered under the plan.
Employers should review their plans and ensure plans are still within compliance and not discriminating against non-Highly Compensated Individuals (HCIs).
HCIs must include the excess benefits provided to them in gross income. Plan sponsor may also face an excise tax or penalty of up to $100 per day per individual discriminated against.

Open Enrollment Deadline
2025-01-01

Happy New Year: Office Closed
2025-01-01

Prohibition on Gag Clauses
2024-12-31
All group medical plans
Plans and carriers may not enter into an agreement with a provider, network, TPA or other service provider offering access to a network of providers that restricts the plan from; providing provider-specific cost or quality of care data, electronically access de-identified claim and encounter data for each participant or beneficiary and sharing such information, consistent with applicable privacy regulations. An attestation of compliance must be filed electronically with CMS each year to attest for the previous plan year.
Employers should coordinate in writing with their Carrier, TPAs or other service providers to verify who will be submitting the attestation and will be meeting with the requirement. Employers are ultimately responsible in completing this task.
No official guidance on penalties have been released as of the creation of this document.

Gag Clause Prohibition Deadline
2024-12-31

Enrollment Deadline For 1st Of The Month
2024-12-31
