Upcoming Deadlines and Reminders for Group Health Plans – 2015 First Quarter

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Summary of Deadlines in Q1 2015

  • January 15 –  Date by which employer who sponsors a self-funded health plan must pay the first installment of the 2014 transitional reinsurance fee ($52.50 per enrollee).  Plan sponsor should have scheduled this payment and submitted enrollment data by December 5, 2014, at Pay.gov.   This Jan. 15th payment can be either the full annual payment ($63 per enrollee), or can be only the first installment ($52.50 per enrollee) and the second installment ($10.50 per enrollee) can be paid by November 15, 2015.  For insured plans, carrier pays the fee.
  • January 31  Deadline to distribute Forms W-2 to employees and former employees, for the 2014 taxable year.  Health & welfare benefits information to include:
    • Group health plan cost/value during 2014, as required by the ACA.
    • Taxable income for coverage provided during 2014 (e.g., life insurance in excess of $50,000 for which the employee did not pay the full Table I rate on an after-tax basis, taxable amounts to highly-compensated employees under discriminatory self-insured group health plans, taxable amounts to key employees under discriminatory life insurance plans).
    • Employer health savings account (HSA) contributions (including employees’ pre-tax HSA contributions) for the 2014 taxable year.
  • February 1 – Employers must post OSHA Form 300A Accident Summary in a public area from February 1 through April 30 for previous year’s accidents (repeat annually).
  • February 2 – Deadline for employers to implement retroactive increase in 2014 Mass Transit Benefit Limit ($130/month, increased to $250/month).
  • February 15 – Open enrollment (for 2015) ends in the Health Insurance Marketplaces (Exchanges).  For individuals who enroll by February 15, coverage will be effective March 1. After February 15, eligible individuals can only enroll if they have a “special enrollment event” such as loss of employer group coverage (not due to failure to timely pay premiums).
  • February 15 or Earlier – Recommended –  Nondiscrimination Testing of section 125 plans and self-funded plan group health plans (if plan year began January 1).  If plans don’t pass nondiscrimination tests based on January 1 enrollment data, employer can make necessary adjustments (if provided in plan document), such as reducing pre-tax contributions of highly-compensated individuals.
  • March 1 or Earlier –  Medicare Part D Online Disclosure  to CMS of Creditable and/or Noncreditable Coverage Status  (The deadline is within 60 days after first day of plan  year, which is March 1 for calendar year plans.  Adjust accordingly for non-calendar year plans.)
  • March 1 or EarlierDeadline to file annual Form M-1 for multiple employer welfare arrangements (MEWAs) that provide health coverage to employees of two or more employers who are not in the same controlled group and are not affiliated service companies.
  • March 30 and 90 days after certain Events– Calendar year plan must distribute Summary Plan Description (SPD).  (Deadline is 90 days after start of plan year, so adjust accordingly.)