Upcoming Compliance Dates

Employers must comply with numerous reporting and disclosure requirements throughout the year in connection with their group health plans.  Listed below are upcoming important compliance deadlines for employer-sponsored group health plans.

Group health plan sponsors that provide prescription drug coverage to Medicare Part D-eligible individuals must disclose to the Centers for Medicare & Medicaid Services (CMS) whether prescription drug coverage is creditable or non-creditable within 60 days after the beginning of the plan year. For plans that renew on January 1, the deadline is March 2, 2021.
Employers with less than 50 employees that sponsor self-insured health plans (including level-funded) are required to report information about the coverage to covered individuals each year, using IRS Form 1095-B. Employers with 50 or more full-time or equivalent employees, known as ALEs, that sponsor fully or self-insured health plans are required to report information to employees using IRS Form 1095-C The forms must be provided to employees by March 2, 2021.

These forms must also be submitted to the IRS. Employers with less than 50 employees who sponsor self-insured health plans (including level-funded) will submit 1094-B and 1095-B.  ALEs that sponsor fully or self-insured health plans will use IRS Forms 1094-C and 1095-C. The deadline for filing paper versions of the forms to the IRS is March 1, 2021. The deadline for electronic filing is March 31, 2021.

EMPLOYERS CAN PROVIDE ADDITIONAL TIME TO USE FSA FUNDS

On Dec. 27, 2020, President Trump signed the Consolidated Appropriations Act of 2021 into law. The Act provides temporary special rules for health and dependent care flexible spending accounts (FSAs) that give employees additional time to use these funds.

Because of the COVID-19 pandemic, employees may be more likely to have unused amounts in health or dependent care FSAs. For plan years ending in 2020 and 2021, the Act allows employers to:

  • Permit employees to carry over unused amounts remaining in these FSAs to the next plan year.
  • Extend the grace period to 12 months after the end of such plan year.
  • Permit employees who cease plan participation during 2020 or 2021 to continue to receive reimbursements from unused amounts through the end of the plan year in which their participation ended.

The Act also allows employees to elect to prospectively modify the amount of their FSA contributions for plan years ending in 2021, even if they have not experienced a change in status. However, the applicable dollar limitations will continue to apply. Employers can retroactively adopt plan amendments incorporating these provisions if specific requirements are met.

EMERSON IS A BIG BROTHER!

We are excited to announce that Colby and Amber welcomed their son Calen Rit McPike into the world on Nov. 25 (6lbs, 6oz). Big brother Emerson’s favorite thing to do with him is to snuggle really close and make Calen smile!

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