Employee Benefits Compliance, Timeline

Upcoming Deadlines and Reminders for Group Health Plans—2014 Fourth Quarter

Summary of Deadlines in Q4 2014

—  October 15 – Medicare Part D notice –  plan sponsor must send to Medicare-eligible participants

—  October 30 – Recommended nondiscrimination testing (125 or self-funded plan) – so plan sponsor can make adjustments (if needed) before year-end

—  November 5 – Group Health Plans must obtain Health Plan Identifier (HPID) – No longer required as of Nov. 5.  Delayed indefinitely, as of Oct. 31.

—  November 15 – Self-funded health plans submit enrollment data to Pay.gov for transitional reinsurance fee (TRF) calculation

—  November 15 – Open enrollment begins in the Health Insurance Marketplaces (Exchanges).  Eligible individuals can enroll or renew enrollment for 2015, and some may qualify for subsidies

—  December 15 – HHS will notify plans of amount of TRF for the year

—  December 15 – SARs (Summary Annual Reports)  – Plan administrator must distribute SARs, if 5500 was filed October 15 (on extension).

—  December 15  Date by which individuals must enroll in Exchange coverage for it to be effective January 1, 2015.

—  December 31  HIPAA certificates of creditable coverage will no longer be required after 2014!

  December 31  Deadline by which employers with Health FSAs must amend plan documents to include several provisions required or allowed in last few years (see details below).

Additional Detail on some of the above

OCTOBER 15, 2014 – Medicare D notice

Group health plan sponsors must provide Medicare Part D “creditable coverage” notices prior to October 15th, the start date of the Medicare annual enrollment period for Part D, Prescription Drug coverage. (The enrollment period is October 15-December 7.) Most plan sponsors use the Model Medicare Part D Notices provided by the Centers for Medicare and Medicaid Services (CMS) to notify affected plan participants. Links to all the model letters (in English and Spanish) are available here.  Applies to plan sponsors of insured, self-funded, large and small plans. Leavitt Article at: https://news.leavitt.com/health-care-reform/employer-action-required-distribute-medicare-part-d-notices-october-15th/



Self-insured health plans must obtain a Health Plan Identifier (HPID) by November 5, 2014.  Small plans (defined as those with annual receipts (claims paid) of $5 million or less) have a one-year delay, to November 5, 2015.  Insured plans are also subject to the requirement, but the carrier will obtain the HPID on behalf of the plan.  (Carrier may direct employer insured plan to also obtain an HPID or plan may elect to obtain one.)  There is no charge to obtain a HPID, and it can be obtained through the CMS Enterprise Portal.
Leavitt Article at: https://news.leavitt.com/health-care-reform/health-plan-identifier-hpid-requirements-process/


NOVEMBER 15, 2014 – Transitional Reinsurance Fee

Self-funded health plans must submit enrollment data to www.Pay.gov  for transitional reinsurance fee (TRF) calculation.  This is based on January through September data, even for non-calendar-year plans. The form will automatically calculate the reinsurance contribution amount due.  The plan or TPA also must submit payment information and schedule a payment date for remittance of the contributions.  Leavitt Article at: https://news.leavitt.com/health-care-reform/cms-guidance-group-health-plans-will-pay-reinsurance-fees/


DECEMBER 15, 2014 – Transitional Reinsurance Fee

HHS will notify plans of amount of transitional reinsurance fee (TRF) for the year. For 2014 the reinsurance fee will be $63 per health care plan enrollee (this includes both employees and dependents) and will decrease in 2015 and 2016.  Of the $63 annual fee, $52.50 per enrollee will be due by January 15, 2015, and $10.50 per enrollee will be due by November 15, 2015.  The reinsurance fee will be tax-deductible as an ordinary business expense.  For fully-insured plans, this fee will be paid by insurers and added onto the rates; self-funded plans are responsible for the fee.


DECEMBER 31, 2014 – Amendments to Health FSAs

Deadline by which employers with Health FSAs must amend plan documents for the following provisions (if applicable):

  • $2,500 annual limit on employee salary reduction contributions – required for all plans
  • $500 carryover allowed for 2013 or 2014 plan year (for calendar year Health FSAs) – optional, only if employer adopted $500 carryover provision
  • One-time midyear election change to allow enrollment  in or disenrollment from employer group health plan during 2013 plan year (non-calendar year plans) – optional, only if employer adopted amendment allowing such midyear election change

PDF of this Article: 10-8-14 Upcoming deadlines and Reminders for GHPs HRU article