In the world of employee benefits, one of the sure signs that fall has arrived is a flurry of articles regarding compliance deadlines to be met before the end of the year. To help you get a jump on next year’s issues, we have also included some of the compliance deadlines that apply early in 2015. If you have any questions about these items or wish to get additional information on them, please contact your Lockton account team.
Oct. 15, 2014
- Deadline for employers with calendar-year plans to file Form 5500 if they obtained an extended due date.
- Deadline for Medicare Part D Notices of creditable or non-creditable prescription drug coverage to Medicare Part D-eligible participants and beneficiaries (unless provided in preceding 12 months).
Nov. 15, 2014
- Open enrollment begins for individuals to obtain coverage for 2015 via the Health Insurance Marketplace.
Dec. 5, 2014
- Deadline for employers, on behalf of their self-insured major medical plans, to report annual enrollment count, and arrange for payment of the transitional reinsurance fee based on that count, using online process available on pay.gov.
Dec. 15, 2014
- Deadline for supplying summary annual reports to participants, for calendar-year plans whose Forms 5500 filing deadlines were extended to Oct. 15, 2014.
- Deadline by which individuals obtaining new Marketplace coverage must complete enrollment in order for that coverage to be in effect on Jan. 1, 2015.
Dec. 31, 2014
- Deadline to amend health FSA plan documents to reflect addition of an up to $500 carryover provision for the 2013 or 2014 plan year (calendar year health FSAs).
- Deadline to amend health FSA plan documents to limit salary reduction contributions during a plan year to $2,500 or less.
- Deadline to amend plan documents of non-calendar year cafeteria plans to reflect addition of one-time midyear election change to enroll in or drop accident or health plan coverage during the plan year beginning in 2013.
- Deadline to distribute Notice of Grandfathered Status (grandfathered, calendar year group health plans); this notice is typically included in plan summaries.
- Deadline to provide notice of patients’ rights regarding selection of network providers (non-grandfathered, calendar year group health plans); this notice is typically included in plan summaries.
- Deadline for supplying Women’s Health and Cancer Rights Act notice (calendar year group health plans).
- Deadline for self-insured state and local government health plans to submit an optional opt-out election to CMS and provide opt-out notice to participants (calendar year group health plans).
- Deadline to provide notices of premium assistance under Medicaid or the Children’s Health Insurance Program (calendar year group health plans).
- Last date on which provision of certificates of creditable coverage is required (currently required under HIPAA portability rules).
Jan. 1, 2015
- Begin providing health coverage to prevent play or pay penalties (subject to various transition rules, including those that apply to employers with non-calendar year plans and employers with fewer than 100 full-time employees).
- Begin tracking reportable health plan values for purposes of reporting on Forms W-2 for the 2015 taxable year (generally due by Jan. 31, 2016).
- Begin tracking individuals provided minimum essential coverage (MEC) during each calendar month under an employer-sponsored self-insured plan for section 6055 reporting for the 2015 calendar year (generally due at the same time as Forms W-2).
- Begin tracking coverage offers made to full-time employees with respect to each calendar month for section 6056 reporting for the 2015 calendar year (generally due at the same time as Forms W-2).
- Non-grandfathered, calendar year group health plans that are not high-deductible health plans offered in connection with health savings accounts must limit in-network out-of-pocket expenses for essential health benefits to no more than $6,600 for self-only coverage and $13,200 for other coverage.
- Such plans may, however, apply separate limits on out-of-pocket expenses for two or more types of essential health benefits so long as all limits on out-of-pocket expenses for in-network essential health benefits total no more than the $6,600/$13,200 overall limits.
- For example, such a plan may limit out-of-pocket expenses for prescription drugs that are essential health benefits to $2,600/$5,200 and apply separate limits of $4,000/$8,000 on out-of-pocket expenses for all other essential health benefits.
- Calendar year high-deductible health plans offered in connection with health savings accounts must limit in-network out-of-pocket expenses to no more than $6,450 for self-only coverage and $12,900 for other coverage.
- Make changes to comply with final MHPAEA regulations, including providing coverage for treatment of mental health and substance abuse disorders in non-hospital settings (e.g., in residential treatment facilities) with no greater cost
sharing than applies to coverage for medical or surgical treatment in non-hospital settings (e.g., skilled nursing facilities) (group health plans plan years
beginning on or after July 1, 2014).
- Begin covering the following preventive services with no cost sharing:
- Hepatitis C screening for adults at high risk for infection, as well as a one-time screening for adults born between 1945 and 1965 (non-grandfathered plans for plan years beginning on or after July 1, 2014).
- Lung Cancer Screening for adults age 55 to 80 years who have a 30 pack-year smoking history and currently smoke or have quit within the past 15 years (non-grandfathered plans for plan years beginning on or after Jan. 1, 2015).
- Electronic submission through the Health Insurance Oversight System becomes the only means for making the opt-out election permitted for self-funded, non-federal governmental plans.
Jan. 31, 2015
- Deadline to report on Forms W-2 for the 2014 taxable year:
- 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).
- Reportable health plan values during 2014 as required by the ACA.
- Employer health savings account (HSA) contributions (including employees’ pre-tax HSA contributions) for the 2014 taxable year.
Feb. 15, 2015
- Last day of Health Insurance Marketplace open enrollment period for coverage during 2015.
March 1, 2015
- Deadline to provide Medicare Part D Creditable and/or Noncreditable Coverage Notices to CMS (calendar year group health plans).
- Deadline for filing annual Form M-1 on behalf of multiple employer welfare arrangements (MEWAs) providing health coverage.