Employee Benefits Compliance

Q3 2016 Deadlines & Reminders for Group Health Plans

Reminders for 2016 Group Health Plans

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

July 1: State & local minimum wage changes:  San Francisco $13/hour; Washington D.C: $11.50/hour, Maryland: $8.75/hour.

July 30: : Summary of Material Modifications (SMM)   (calendar year 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:  Major medical plans must pay PCORI Fee (for prior plan year).

  • Sponsors of self-funded plans must pay the PCORI fee.  Carrier pays for insured plans.
  • File Federal Tax Form 720 to pay the PCORI fee.
  • Amounts: (See IRS Notice 2015-60)
  • $2.17  for plan/policy years that end on or after Oct. 1, 2015, and before Oct. 1, 2016;
  • $2.08  for plan/policy years that end on or after Oct. 1, 2014, and before Oct. 1, 2015

August 1: DOL penalties assessed after August 1 will be increased for inflation, as provided in DOL Fact Sheet at https://www.dol.gov/ebsa/pdf/fs-interim-final-rule-adjusting-erisa-civil-monetary-penalties-for-inflation.pdf .  Examples:  Penalty for failure to file Form 5500 will increase from $1,100 to $2,063 per day. Penalty for failure to provide a Summary of Benefits and Coverage will increase from $1,000 to $1,087 per failure.  Penalty for failure to furnish information requested by DOL will increase from $100 to $147 per day.

August 1: Government contractors must submit a VETS 4212 (formerly VETS 100), between August 1 and September 30.  Find reporting information at https://www.dol.gov/vets/vets4212.htm .

August 1: Minnesota state minimum wage increases to $9.50/hour for large employers, and $7.75/ hour for small employers.

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

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).

September 30: Organizations with 100+ employees must submit the EEO-1 report by September 30. Proposed EEO-1 form for 2016 is at  https://www.eeoc.gov/employers/eeo1survey/2016_new_survey.cfm .  (In 2015 the deadline was extended from 9/30 to 10/30.  This could happen again in 2016.)

September 30: Last day by which government contractors must submit a VETS 4212.  See above under August 1 for more information, or link to https://www.dol.gov/vets/vets4212.htm .