Employee Benefits Compliance, PCORI Fee

Upcoming Deadlines and Reminders for Group Health Plans – 2015 3rd Quarter

leavitt number updates

This is Leavitt’s Quarterly Update of Deadlines and Reminders in the upcoming quarter. This is for third quarter of 2015.

June 30: Transition relief under Notice 2015-17 ends for Employer Payment Plans offered by small employers (with fewer than 50 employees).

  • Small employers that continue to pay for employees’ premiums for individual health insurance will be subject to $100/day excise tax (IRC 4980D) for each affected employee.
  • Click here for prior Leavitt article.

July 1: Current California employees (part-time and full-time) begin to accrued paid sick time as of July 1.

  • Employees can accrue up to three days of paid sick leave per year (lump-sum method) or 1 hour for every 30 hours worked, which employers can cap use at 6 days per year.
  • Prior Leavitt articles are here and here.

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:  Major medical plans must pay PCORI Fee (for prior plan year).

  • Sponsors of self-funded plans must pay the PCORI fee.  For insured plans, the carrier pays the fee.
  • File Federal Tax Form 720 to pay the PCORI fee.
  • To read Leavitt’s 2015 reminder on PCORI fee, click here.

September 30: Carriers who do not meet medical loss ratio (MLR) limits must send MLR Rebates and Notices of rebates to policyholders.

  • To read Leavitt’s 2014 article on MLR rebates, click here.

September 30 or Earlier: Summary Annual Report (SAR) is due (unless an application for Form 5500 extension was timely filed) for calendar year ERISA plans that were required to file a Form 5500.  For plans on extension, the SAR is due 2 1/2 months after the Form 5500 is due (or filed, if earlier).