Employee Benefits Compliance, Reporting Requirements

2016 Q2 Deadlines & Reminders for Group Health Plans

reminders

This is Leavitt’s Quarterly Update of Deadlines and Reminders for group health plans. This is for second quarter of 2016.

Leavitt provides this quarterly list to help group health plan sponsors identify significant due dates in the upcoming quarter.  This is not intended to identify ALL due dates or compliance obligations.  Also, information is subject to change if government agencies issue additional or clarifying guidance.  Leavitt is not a law firm, and this list is not intended to replace or supercede the advice of your legal counsel.

  • May 16Deadline by which employers who are required to file information reporting forms (1094-C/1095-Cs) electronically can file Form 8508 – Request for Waiver from Filing Information Returns Electronically.  (Generally, an entity must file electronically if it is required to file more than 250 of the same form.) Form 8508 must be submitted at least 45 days before the due date of the returns (May 16 for June 30 due date). Failure to timely file electronically or to file Form 8508 may result in penalties of up to $250 per return.
    NOTE:  It appears that filing Form 8508 would result in hard-copy filing due May 31.
  • May 31 – Deadline by which employers subject to the new information reporting requirements must file hard-copy information returns with the IRS. Employers filing fewer than 250 of any type of form may file hard copies, but may also elect to file that form electronically even though not required to do so. Information returns are comprised of the 1094-C and 1095-Cs for applicable large employers (ALEs), and 1094-B and 1095-Bs for small employers with self-insured plans.
    > This deadline originally was Feb. 29, but IRS Notice 2016-4 delayed it to May 31.
    > Note that filers may no longer request an automatic 30-day extension (Form 8809), since the filing date has been delayed for more than 30 days from the original due date.
  • June 30 – Deadline by which applicable large employers (ALEs) must file information returns with the IRS if filing electronically. Filing must include 1094-C and associated 1095-Cs. Generally, an entity required to file more than 250 of the same form must file electronically, unless the entity filed a Form 8508 by May 16, 2016. Also, small employers with self-insured plans who elect to file electronically must file 1094-Bs and 1095-Bs with the IRS by March 31, 2016.
    > This deadline originally was March 31, but IRS Notice 2016-4 delayed it to June 30.
    > Note that filers may no longer request an automatic 30-day extension (Form 8809), since the filing date has been delayed for more than 30 days from the original due date.