Employee Benefits Compliance

2018 Q1 Deadlines and Reminders for Group Health Plans

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This is Leavitt’s Quarterly Update of Deadlines and Reminders in the upcoming quarter. This is for first quarter of 2018.

  • January 1 – U.S. federal minimum wage rate is $7.25 per hour. California minimum wage increases to $11.00 per hour for employers with 26 or more employees and $10.50 per hour for employers with fewer than 26 employees. Additional information on California wages is at https://www.dir.ca.gov/dlse/faq_minimumwage.htm To check minimum wage rates in each state, see DOL website. https://www.dol.gov/whd/minwage/america.htm .
    • Note that many cities have higher minimum wage laws. Where applicable, these supercede the lower state minimum wage amounts.
  • January 1 – Coverage starts for those who enrolled or changed plans in Marketplace/Exchange individual policies by December 15.
  • January 31 – Deadline by which all employers must provide W-2s to employees for 2017 calendar year. In additional to compensation and withheld taxes, W-2s also must include information on certain employee benefits, such as imputed income for group-term life insurance, employer Health Savings Account Contributions. Also, employers who furnished at least 250 W-2s for 2016 must include in the 2017 W-2s the total cost of employer-provided group health coverage (Box 12,use Code DD).
  • February 14 – Deadline by which employers who are required to file information reporting forms electronically can file Form 8508 – Request for Waiver from Filing Information Returns Electronically. Must be submitted at least 45 days before the due date of the returns (February 15 for March 31 due date). Failure to timely file electronically or to file Form 8508 may result in penalties of up to $260 per return. NOTE: It appears that filing Form 8508 would result in hard-copy filing due February 28.
  • February 15 or Earlier – Recommended – Nondiscrimination Testing, for calendar-year 125 plan or self-funded plan, so employer can make any needed adjustments.
  • February 28 – Date by which hard-copy information reporting forms (1094-C and 1095-C) are due to IRS. Employers filing fewer than 250 of any type of form are not required to file that form electronically but may 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.
  • March 1 or Earlier – Medicare Part D Online Disclosure to CMS of Creditable Coverage Status (March 1 deadline applies for calendar year plans; deadline is within 60 days after first day of plan year.) Employers go online to https://www.cms.gov/Medicare/Prescription-Drug-Coverage/CreditableCoverage/CCDisclosureForm.html
  • March 1 – Date by which the Office for Civil Rights (OCR) must be notified if a breach of PHI occurred during 2017 and it involved the PHI of fewer than 500 individuals.     Covered entities (such as group health plans) must track any breaches of unsecured PHI in a log, and that must be submitted to OCR within 60 days after the end of each calendar year.
  • March 1 – Deadline by which multiple employer welfare arrangements (MEWAs) providing health coverage must file annual Form M-1. Form is for the prior calendar year, and must be filed electronically.
  • March 2 (delayed from January 31) – Employers who are subject to the ACA employer mandate must provide full-time employees with an IRS form 1095-C to document group health coverage they were offered or enrolled in during 2017. Also, small employers who offer self-funded plans must furnish 1095-Bs to full-time and part-time employees who enrolled in the self-funded group health plan at any time in 2017.
  • March 30 and 90 days after certain Events – Summary Plan Description (SPD). (calendar year plans).
  • April 2 (because March 31 is a Saturday) – Deadline by which electronic information reporting forms (1094-C & 1095-C) are due to IRS. Generally, an entity required to file more than 250 of the same form must file electronically, unless the entity filed a Form 8508 by February 15, 2018. Also, small employers with self-insured plans who elect to file electronically must file 1094-Bs and 1095-Bs with the IRS by April 2, 2018.
  • March 31 – Deadline by which employers with at least 100 employee and employers with federal government contracts of $50,000 or more and at least 50 employees must submit their 2017 EEO-1 report to the EEOC (Equal Employment Opportunity Commission). Click here for EEO-1 reporting information. Note that the pay data collection aspect of the EEO-1 form, previously announced by the EEOC, has been suspended under the Trump administration.