Employee Benefit Broker & Health Insurance Agency in NJ

Medicare Open Enrollment Starts
2024-10-15

Medicare Part D Notices to participants
2024-10-15
Group health plans that provide Rx coverage to Individuals eligible for Medicare Part D
Employers must notify Medicare Part D-eligible individuals by Oct. 15th of each year about whether the Rx coverage is creditable or non-creditable as discussed above.
No specific penalty for employers. Potential penalty for individuals who do not maintain creditable coverage.

Form 5500 (Extended deadline)
2024-10-15
ERISA-covered group health plans that do not qualify for the small plan exemption and MEWAs (and have timely requested an extension to the filing deadline)
An employer may request a one-time extension of 2.5 months by filing a Form 5558 by the normal due date of Form 5500. Employers are required to file an annual Form 5500 by October 15th 2024 after a Form 5558 was submitted before the July deadline, which automatically granted an extension up to 2.5 months.
Up to $2,586 per day for late filing. Delinquent Filer Voluntary Compliance (DFVC) program could allow for reduced penalties.

Sukkot: Office Closed
2024-10-17 - 2024-10-18, 2024-10-22 - 2024-10-23

Horizon Conversion Deadline For The Upcoming 1st Of The Month
2024-10-20, 2024-11-20, 2024-12-20, 2025-01-20

Quarterly Report Deadline
2024-10-31

Enrollment Deadline For 1st Of The Month
2024-10-31, 2024-11-30, 2024-12-31

Open Enrollment Starts
2024-11-01

Employer Penalty: Identify application and method of compliance
2024-11-01, 2024-12-01
All Employers
Determine ALE Status (i.e., whether the employer has at least 50 full-time employees (FTEs) each calendar year, considering all common law employees in the entire controlled group and counting each part-time employee as a fraction of the FTE). Determine full-time status using monthly measurement method or look-back measurement method. Offer coverage to FTEs and dependent children. Evaluate minimum value, affordability and elect a safe harbor. Ensure that all plan language accurately reflects the selections.
“A” Penalty Adjusted for inflation: $2,970 for 2024 times total number of FTEs after the first 30 are removed for relief.
“B” Penalty Adjusted for inflation: $4,460 for 2024 times the total number of ACA FTEs who receive the subsidy in the Marketplace (max penalty is capped at the “A” penalty)

Identify FTE status eligibility using the Standard Measurement Period (SMP), Stability Period (SP) and Administrative Period (AP)
2024-11-01
Employers that are an Applicable Large Employer and have variable hour part-time employees.
There are two methods for determining full-time employee status. The monthly measurement method or the look-back measurement method. Zywave has more detailed information on each method and reasons an employer may prefer one method over another.
“A” Penalty Adjusted for inflation: $2,970 for 2024 times total number of FTEs after the first 30 are removed for relief.
“B” Penalty Adjusted for inflation: $4,460 for 2024 times the total number of ACA FTEs who receive the subsidy in the Marketplace (max penalty is capped at the “A” penalty)

Measure Plan Affordability
2024-11-01
Employers that are An Applicable Large Employer
There are three safe harbors that an employer may use to determine affordability for purposes of the employer shared responsibility provisions. Employers are allowed to choose from using either the Form W-2 wages, an employee’s rate of pay or the federal poverty limit to make their affordability determination. The contribution percentage to determine affordability for Plan Years starting in 2024 is 8.39%
2024 percentage is a significant decrease from previous years.
“A” Penalty Adjusted for inflation: $2,970 for 2024 times total number of FTEs after the first 30 are removed for relief.
“B” Penalty Adjusted for inflation: $4,460 for 2024 times the total number of ACA FTEs who receive the subsidy in the Marketplace (max penalty is capped at the “A” penalty)

Horizon Enrollment Deadline For 15th Of The Month
2024-11-14, 2024-12-14, 2025-01-14

Individual Mandate Reporting for Employers with Employees in specific cities or states
2024-11-15 - 2024-12-16
Employers with employees that reside in the state of Massachusetts
Provide a complete HIRD form for MA resident employees.
There are no fines or penalties related to a completed HIRD Form.

Medicare Open Enrollment Deadline
2024-12-07

SAR(Extended deadline)
2024-12-16
Group health plans that are subject to the Form 5500 filing and have extended the deadline via a Form 5558
If an extension of time to file Form 5500 is obtained, the plan administrator must furnish the SAR within two months after the close of the extension period. Employers must provide the SAR to participants by December 16th, 2024.
No monetary penalty for failure to timely distribute, however Up to $110/day if not provided to participant within 30 days of request.

Gag Clause Prohibition Deadline
2024-12-31

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.

Happy New Year: Office Closed
2025-01-01

Open Enrollment Deadline
2025-01-01

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.

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.
