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Health Insurance Plan Compliance Deadlines for 2019

Employers that sponsor group health plans face a number of reporting deadlines throughout the year. For your convenience, here’s a brief reference of key deadlines for calendar year 2019.

January 31

Most everyone is aware that W-2 forms for the previous calendar year must be issued by January 31, but employers that filed more than 250 IRS Forms W-2 must also include the aggregate cost of employer-sponsored health care coverage on these forms.

February 28

Several deadlines coincide with the end of February: Applicable large employers (ALEs) must complete their Section 6056 reporting using IRS Forms 1094-C and 1095-C.

Employers that are not ALEs and that sponsor self-insured health plans must complete Section 6055 reporting using IRS Forms 1094-B and 1095-B.

And employers that are ALEs and sponsor self-insured health plans must complete Sections 6055/6056 reporting, again using IRS Forms 1094-C and 1095-C.

Note that for all three of these instances, February 28 is the deadline for paper filing. Electronic filing is due April 1.

March 1

Group health plan sponsors that provide prescription drug coverage to Medicare Part D-eligible individuals must disclose to the Centers for Medicare & Medicaid Services (CMS) whether prescription drug coverage is creditable or noncreditable, meaning whether it is or is not at least as good as Medicare Part D coverage. March 1 is the deadline for calendar year plans, with reporting done via CMS’ online disclosure form.

March 4

Employers falling into the three categories listed above under the February 28 deadline must provide individual employee statements under Section 6055 and/or Section 6056 by March 4. This is an extension of the normal January 31 deadline for calendar year 2018 reporting only.

April 1

As noted above, April 1 is the electronic filing deadline for reporting under Sections 6055 and 6056. The normal deadline here is March 31, but as that falls on a Sunday in 2019, the deadline is extended to April 1.

July 31

Employers with self-insured health plans must pay an annual fee to fund the Patient Centered Outcomes Research Institute (PCORI). Self-insured health plans that are subject to PCORI fees include self-funded medical plans, as well as HRAs offered in conjunction with fully insured group medical plans. This reporting is done using IRS Form 720. Note that the PCORI fees are temporary, and do not apply to plan years ending on or after October 1, 2019.

A July 31 deadline is also in effect for employers with ERISA-covered welfare benefit plans, who are required to file an annual Form 5500, unless a reporting exemption applies. Small health plans covering fewer than 100 employees that are fully insured, unfunded or a combination of the two, are generally exempt from this requirement.

September 30

For employers with fully-insured health plans that receive medical loss ratio (MLR) rebates: Issuers must spend a minimum percentage of their premium dollars, or MLR, on medical care and health care quality improvement. Issuers that do not meet the applicable MLR must pay rebates to consumers. Rebates must be provided to plan sponsors by Sept. 30 following the end of the MLR reporting year.

Also, employers that are required to file a Form 5500, also known as a summary annual report (SAR) for their group health plan must do so within nine months of the close of the plan year. For calendar year plans, this deadline is September 30.

October 14

Employers with group health plans that provide prescription drug coverage must notify Medicare Part D-eligible individuals by October 14 regarding whether that coverage is creditable or non-creditable, as defined above. This notice may be included in open enrollment materials if the open enrollment period begins on or before October 14.

October 15

Employers with ERISA-covered welfare benefit plans who are required to file an annual Form 5500 as noted above under the July 31 heading may request an extension by filing IRS Form 5558. If the Form 5558 is filed on or before the normal deadline, an extension is automatically granted, moving the deadline to October 15 for calendar year plans.

Questions about benefits or deadlines? Contact Consolidated Insurance.