Benefits Compliance, Employee Benefits Compliance

2017 Q1 Deadlines and Reminders for Group Health Plans

2017 calendar

This is Leavitt’s Quarterly Update of Deadlines and Reminders in the upcoming quarter. This is for first quarter of 2017.

  • January 1—U.S. federal minimum wage rate is $7.25 per hour. California minimum wage increases to $10.50 per hour for employers with 26 or more employees and is $10 per hour for employers with fewer than 26 employees.  To check minimum wage rates in each state, see DOL website. . (Just FYI, as of Jan. 1, 2017, the minimum wage in Russia will increase to 7,500 rubles ($125) per month (up from 6,204 rubles ($87) in 2016). This includes compensation, incentives payment and social benefits, per ; and for conversion of rubles to dollars,
  • January 1Coverage starts for those who enrolled or changed plans in Marketplace/Exchange individual policies by December 15.
  • January 16Date by which employer who sponsors a self-funded health plan must pay the first installment of the 2016 transitional reinsurance fee. For insured plans, carrier pays the fee. Plan can make one-time payment of total annual fee ($27 per enrollee), or can pay first installment of $21.60 per enrollee now and second installment of $5.40 per enrollee by November 15, 2017. Access to pay; for information see
  • January 15Last day for individuals to enroll in or change plans in the Marketplace/Exchange and have new coverage to start February 1, 2017.
  • January 20Inauguration Day for President Donald Trump and Vice-President Mike Pence.
  • January 31Deadline by which all employers must provide W-2s to employees for 2016 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 2015 must include in the W-2s the total cost of employer-provided group health coverage (Box 12,use Code DD).
  • January 31Marketplace Open Enrollment ends. Enrollments or changes between January 16 and January 31 take effect March 1, 2017.
  • February 14Deadline 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 – RecommendedNondiscrimination Testing, for calendar-year 125 plan or self-funded plan, so employer can make any needed adjustments.
  • February 28Date 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 EarlierMedicare 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
  • March 1Date by which the Office for Civil Rights (OCR) must be notified if a breach of PHI occurred during 2016 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 1Deadline 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 2Deadline by which applicable large employers (ALEs) must furnish 1095-Cs to all full-time employees, and if self-funded,  to employees who were not full-time but who enrolled in employer group coverage at all during 2016. Small employers with self-insured plans must furnish 1095-Bs to employees who were enrolled in self-insured coverage at any time in 2016.   (This deadline originally was Jan. 31, but IRS Notice 2016-70 delayed it to March 2.)
  • March 30 and 90 days after certain EventsSummary Plan Description (SPD). (calendar year plans).
  • March 31Deadline 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 14, 2017. 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.