Upcoming Compliance Deadlines and Tasks for Employer-Sponsored Group Health Plans

Upcoming Compliance Deadlines and Tasks for Employer-Sponsored Group Health Plans

It is a busy time of year for employers and employees alike.  When a lot is going on, it is easy to forget things.  Make sure you mark your calendars for these upcoming health plan compliance tasks and deadlines. 

Preventive Care Review

All non-grandfathered health insurance plans must cover specific preventive care services without imposing any cost-sharing requirements on the patient. Before 2021 begins, group health plan sponsors should ensure their coverage scope meets the latest standards. The easiest way to check is to look at the Kaiser Family Foundation’s Preventive Care Services Tracker since it pulls all of the recommendations for adults together in one place and dates each change. For children’s services, you should check the guidelines published by the Health Resources and Services Administration’s (HRSA’s) Bright Futures Project.

New Summary of Benefits and Coverage and Uniform Glossary Templates for 2021

Every group health plan needs to distribute a Summary of Benefits and Coverage for each plan option and a Uniform Glossary of healthcare terms to plan participants at enrollment, on request, and in other specific instances. These documents must follow specific federal templates, and the templates have changed. All plans beginning on or after January 1, 2021, need to use the new forms. While health insurance carriers and third-party administrators typically supply these documents, the employer plan sponsor still needs to verify that employees get the correct version. 

W-2 Reporting

Businesses must distribute 2020 Form W-2 statements to employees by January 29, 2021 (because January 31, 2021, is a Sunday). All employers who file 250 or more Forms W-2 with the Internal Revenue Service (IRS) must report the cost of any group health insurance coverage they provide to any employee in Box 12 of the employee’s Form W-2. Employers who file less than 250 Forms W-2 in a calendar year (those not subject to the electronic filing requirements) may report an employee’s health coverage cost information in Box 12 voluntarily. 

Medicare Creditable Coverage Certification

Within 60 days of the first day of the plan year, employers that offer prescription drug benefits to any Medicare-eligible people must file an online disclosure form with the Centers for Medicare and Medicaid Services (CMS). For calendar-year plans, the deadline is March 2, 2021. The disclosure indicates if the employer-plan drug benefit is “creditable,” meaning that it will cover, on average, as much as the standard Medicare Part D prescription drug plan.  Since it is impossible to know if a plan participant will become Medicare-eligible during a given year, all plans that offer prescription drug benefits should complete the disclosure. 

Employer Reporting Deadlines

There are critical deadlines that businesses with reporting obligations need to keep in mind.

Form 1094 Transmissions

Paper filers must mail their transmittal of Form 1094 B or C and copies of all Forms 1095 B or C to the IRS by February 26, 2021 (because February 28, 2021, is a Sunday). Only employers and issuers who issue less than 250 forms in the calendar year may submit using paper filings. 

Electronic filers must submit Form 1094 B or C and all Forms 1095 B or C to the IRS by March 31, 2021. 

Form 1095 Statements

Applicable large employers and health insurance issuers must distribute Form 1095 statements to eligible employees and covered individuals by March 2, 2021. 

SPDs and COBRA Notices

New plan participants must get a summary plan description (SPD), and employees and any eligible spouses must receive a copy of the COBRA general notice within 90 days of the start of coverage.  This rule doesn’t just apply to newly eligible employees but also to people who join the plan for the first time during open enrollment.  For plan years that start on January 1, the deadline to give new participants these notices is April 1, 2021.

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