Employee Benefits Compliance

2017 Q3 Deadlines and Reminders for Group Health Plans

calendar year

This is Leavitt’s Quarterly Update of Deadlines and Reminders in the upcoming quarter. This is for third quarter of 2017 (July – Sept).  This list generally applies to group health plans and plan sponsors, not to retirement or 401(k) plans.


July 31 or Earlier: Form 5500 is due (unless an extension is requested) for calendar year ERISA plans that had at least 100 employee participants on the first day of the plan year (or that held plan assets in a trust even if had fewer than 100 participants).

July 31 or Earlier:  Sponsors of self-funded major medical plans must pay the PCORI Fee for plan years that ended in 2016. File IRS Form 720. For insured plans, the carrier pays the PCORI fee.   PCORI Fee amount per enrollee (employees and dependents):

  • $2.26  for plan years that ended Oct. 1, 2016 – Dec.31, 2016
  • $2.17  for plan years that ended Jan. 1, 2016 – Sept. 30, 2016

August 1: Government contractors must submit a VETS 4212 (formerly VETS 100), between August 1 and September 30. Reports filed prior to August 1 will be considered part of the prior year’s (2016) cycle. Find reporting information at https://www.dol.gov/vets/vets4212.htm .

September 30: Carriers who do not meet medical loss ratio (MLR) limits must send MLR Rebates and Notices of rebates to policyholders. For an insured ERISA plan, the policyholder is the plan sponsor.

September 30 or Earlier: Summary Annual Report (SAR) is due to plan participants for calendar year ERISA plans that were required to file a Form 5500, unless an application for an extension was timely filed.  For plans on extension, the SAR is due 2 1/2 months after the Form 5500 is due (or filed, if earlier).  (Note:  The 5500 is technically called the “Annual Report” – and the SAR is a summary of (some of) the information on the 5500.)

September 30: The 2017 EEO-1 form will NOT be due by September 30. Organizations with 100+ employees must submit the EEO-1 report. These were due by Sept. 30, but the 2017 EEO-1 form will be changing. Reports must be submitted and certified by March 31, 2018. For information, see https://www.eeoc.gov/employers/eeo1survey/2017survey.cfm