Compliance Overview

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New York, USA - 5 September 2014: Monochrome view looking up at the New York State Supreme Court Building and the US Justice Building, in Lower Manhattan, New York.

Annual Compliance Deadlines for Health Plans

Employers that provide group health plan coverage to their employees are subject to numerous compliance requirements throughout the year, such as requirements for reporting, participant disclosure and certain fee payments. For example, employers with group health plans may be required to:

  • File a Form 5500 by the last day of the seventh month following the end of the plan year (or request a filing extension);
  • Provide Medicare Part D creditable coverage disclosures to plan participants by Oct. 15 of each year; and
  • Pay Patient-Centered Outcomes Research Institute (PCORI) fees by July 31 of each year.

This Compliance Overview contains a high-level summary of the various compliance requirements and associated deadlines that health plan sponsors should be aware of throughout the year. It also summarizes annual notice requirements for group health plans. Please note that certain deadlines for non-calendar year plans may vary from what is outlined below.

CALENDAR YEAR DEADLINES

This chart only addresses recurring calendar year compliance deadlines. The chart does not include other requirements that are not based on the calendar year. For example, a plan administrator must provide a COBRA Election Notice to a qualified beneficiary after a qualifying event occurs. This type of notice requirement is not addressed in the chart below. Also, state laws may impose additional obligations. Users of this chart should refer to the specific federal or state law at issue for complete information.

Annual Deadlines

  • Employers that sponsor group health plans are subject to numerous compliance requirements throughout the year.
  • Not all of these compliance requirements will apply to every employer.
  • For example, only employers with self-insured health plans are required to pay PCORI fees.

Action Steps

  • Health plan sponsors should work with their advisors to determine which recurring deadlines apply to them.
  • In addition to the compliance requirements described in this chart, it’s important for plan sponsors to monitor legislative and regulatory developments.

Annual Compliance Deadlines