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Compliance deadlines for health and welfare plans continue to abound as we start 2015. In the listing below, we focus on compliance deadlines during the first half of 2015. Although Jan. 1 has passed, we have also included items having compliance deadlines related to plan years beginning during 2015. (For Jan. 1, 2015 and fourth quarter 2014 compliance deadlines, see our Oct. 13, 2014 post.) If you have any questions about compliance deadlines, or wish to get additional information on them, please contact your Lockton account team.

Jan. 31, 2015

  • Deadline to issue Forms W-2 for the 2014 taxable year that include:
    • Taxable income for certain 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, and health coverage for non-dependent domestic partners paid by employer or by employee on pre-tax basis).
    • Reportable health plan values during 2014 as required by the ACA (exemption for small employers).
    • Employer and employee pre-tax health savings account (HSA) contributions for the 2014 taxable year.

Feb. 15, 2015

  • Last day of Health Insurance Marketplace open enrollment for coverage during 2015.

March 1, 2015

  • Deadline to provide Medicare Part D Creditable and/or Non-creditable 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 unless they meet a filing exemption.

April 14, 2015

  • For group health plans that became subject to HIPAA privacy rules on April 14, 2003 and are self-insured, deadline for reminder notice regarding health plan’s HIPAA Privacy Notice (due every third year, unless otherwise provided, such as in enrollment packets; insurer provides for insured coverage).

July 31, 2015

  • Deadline for employers to file Form 720 and pay PCORI fee with respect to self-insured calendar-year health plans and other self-insured health plans that have plan years ending on or after October 1, 2014 and before January 1, 2015.
  • Deadline to file Form 5500 for plan years ending Dec. 31. 2014 (unless extension is obtained).

Various Dates (as indicated)

  • Make changes to comply with final Mental Health Parity and Addiction Equity Act (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). Applies to group health plans for plan years beginning on or after July 1, 2014.
  • For employers not required to do so starting Jan. 1, 2015, begin providing health coverage to prevent play or pay penalties (subject to various exceptions, caveats and transition rules, including those that apply to employers with non-calendar year plans and employers with fewer than 100 full-time employees).
  • Non-grandfathered health plans begin covering the following preventive services with no cost sharing:
    • Healthy diet and physical activity counseling for adults at risk of cardiovascular disease (for plan years beginning on or after Sept. 1, 2015).
    • Hepatitis B screening for persons at risk for infection (for plan years beginning on or after June 1, 2015).
    • Hepatitis C screening for adults at high risk for infection, as well as a one-time screening for adults born between 1945 and 1965 (for plan years beginning on or after July 1, 2014).
    • Lung cancer screening for certain current and former smokers who are 55 to 80 years of age (for plan years beginning on or after Jan. 1, 2015).
  • Non-grandfathered group health plans (other than 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. Applies for plan years beginning in 2015.
    • 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.
    • CAUTION: High-deductible health plans offered in connection with health savings accounts must, for plan years beginning in 2015, limit in-network out-of-pocket expenses to no more than $6,450 for self-only coverage and $12,900 for other coverage.