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2016 Q1 DEADLINES and REMINDERS for Group Health Plans: Updated!

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Updated December 31, 2015, to change information reporting deadlines, per IRS Notice 2016-4. 

This is Leavitt’s Quarterly Update of Deadlines and Reminders in the upcoming quarter. This is for first quarter of 2016.

  • January 1 – California minimum wage increases to $10 per hour.  (Just FYI, as of Jan. 1, 2016, the minimum wage in Russia will increase to $87 per month (6,204 rubles), under a decree signed by President Vladimir Putin.   http://www.themoscowtimes.com/article/552867.html )
  • January 1 Coverage starts for those who enrolled or changed plans in Marketplace/Exchange individual policies by December 15.
  • January 15Date by which employer who sponsors a self-funded health plan must pay the first installment of the 2015 transitional reinsurance fee. For insured plans, carrier pays the fee. Plan can make one-time payment of total annual fee ($44 per enrollee), or can pay first installment of $33 per enrollee now and second installment of $11 per enrollee by November 15, 2016.  Access www.pay.gov to pay.
  • January 15Last day for individuals to enroll in or change plans in the Marketplace/Exchange and have new coverage to start February 1, 2016.
  • January 31 – Marketplace Open Enrollment ends. Enrollments or changes between January 16 and January 31 take effect March 1, 2016.
  • February 1 Deadline by which all employers must provide W-2s to employees for 2015 calendar year.   (Note that this due date is one day later than the standard January 31 deadline because January 31, 2016 is a Sunday).   See March 31 entry below for an information reporting deadline that was delayed from Feb. 1 to March 31.
  • February 15 or Earlier – RecommendedNondiscrimination Testing, for calendar-year 125 plan or self-funded plan, so employer can make any needed adjustments.
  • February 29 – No longer the deadline by which hard-copy information reporting forms are due.  See new entry under May 31.
  • 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.)
  • 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 30 and 90 days after certain EventsSummary Plan Description (SPD). (calendar year plans).
  • New!  March 31 – Deadline 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 2015.  Small employers with self-insured plans must furnish 1095-Bs to employees who were enrolled in self-insured coverage at any time in 2015.   (This deadline originally was Feb. 1, but IRS Notice 2016-4 delayed it to March 31.)
  • March 31 –  No longer the deadline by which electronic information reporting forms are due.  See new entry under June 30.


 Deadlines originally in first quarter, moved to after first quarter per IRS Notice 2016-4:

  • New!  May 16 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 (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 Mary 31.
  • New!  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 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.   (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 date.)
  • New!  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 February 14, 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 date.)