Organizations that offer group health coverage for their workers are subject to compliance requirements throughout the year. Use a compliance calendar to stay on top of important deadlines.
As the new year takes hold, smart owners are planning ahead for the year in every aspect of their business, and setting goals for sales, production, and employees.
If you’re a business owner, take the time to create a plan for the coming year when it comes to benefits administration, as well. The Zenefits’ 2020 Compliance Calendar can help you get organized, meet all regulatory needs, and make it easier to manage your employee benefits plan responsibilities.
Organizations that offer group health coverage for staff members are subject to a variety of compliance requirements throughout the year. These include reports, payments, and participant disclosures.
Some are date-specific deadlines, others are based plan-specific:
- Date-specific deadlines are not flexible: they recur every year at the same time
- Plan-specific deadlines only occur when a qualifying event triggers the need for action
Here are some of the most common compliance deadlines to mark on your calendar.
Annual date-specific compliance deadlines
January 31: Form W-2 including cost of group health insurance
W-2 forms are issued to employees on or before January 31 of each year. For businesses that provide group health coverage, the cost of the benefit must be included in Box 12 of the employee’s Form W-2 (see page 29 of this form for details).
Small and medium-sized businesses who file 250 or more W-2s are required to provide the cost; for employers who file less than 250 W-2s, reporting is voluntary.
February 28: Self-insured health plan reports
Employers required to offer healthcare benefits under the Affordable Care Act (ACA), must submit information to employees and the IRS on each enrolled participant using Forms 1094-C and 1095-C annually. This includes employers with 50 or more full-time or full-time equivalent (FTE) employees and Applicable Large Employers (ALEs).
- Form 1094-C gives the IRS a summary of all eligible and enrolled employees
- The 1095-C form is issued to each employee with a copy to the IRS, providing detailed information
July 31: Patient-Centered Outcomes Research Institute forms and fees
Under the ACA, some health plan sponsors and self-insured plans pay a fee to fund research that helps employees, clinicians, and others make informed health decisions by “advancing the quality and relevance of evidence-based medicine.”
The IRS collects Form 720 and fees that are due for the previous year. Some insured health plans are responsible for the notice and payment, while self-insured plans are paid for by the plan sponsor.
October 15: Medicare creditable coverage notices
If your healthcare plan provides prescription drug coverage, the Medicare Modernization Act (MMA) requires 2 notices of disclosure. These inform plan holders, and any covered dependents, whether the prescription drug coverage is “creditable coverage” — meaning it typically pays out as much as standard Medicare prescription drug coverage.
The first written notice goes to employees and their covered dependents. The second is an Online Disclosure to CMS (Centers for Medicare and Medicaid Services) to report the creditable coverage status of the prescription drug plan.
Benefits Plan-Specific Compliance Deadlines
These deadlines change throughout the year and are triggered by a qualifying event:
Within 14 days of new hire: Health insurance notification
All new hires must receive a notification about health insurance marketplaces, coverage options in the individual market, and any information about your group health insurance.
New hire and open enrollment
During open enrollment and when a new hire becomes eligible to join your plan, these 3 documents, minimally, must be provided:
- A Summary of Benefits and Coverage (SBC) which provides a summary of coverage and estimates of the cost of commonly used services
- Women’s Health and Cancer Rights Notice
- HIPAA Special Enrollment Rights Notice
There may be other notifications required, depending on the type of healthcare plan and your state.
Within 14 days of a qualifying event: COBRA notification
When employees, or their covered dependents, qualify for continuing healthcare coverage under Consolidated Omnibus Budget Reconciliation Act (COBRA), notification of eligibility, cost, and instructions to continue coverage must be sent within 14 days of the event. Covered dependents include spouses, ex-spouses, and dependent children.
Within 90 days of plan enrollment: Summary Plan Document
Whenever an employee chooses coverage under an employer-sponsored healthcare plan, they are entitled to a copy of the Summary Plan Document. This notification provides detailed information on the coverage and benefits the plan provides. Bonus tip: Make sure you have Workers’ Compensation Insurance to protect your business, your employees and yourself!
Mark your calendar for the date-specific deadlines and be ready to comply with notifications required by your specific health plan. There are many more date-specific and annual notifications required to comply with a variety of laws under the ACA, FLSA, and Department of Labor regulations.
FYI — for government filings, if the due date falls on a legal holiday or weekend, you have until the next business day to file.