What are the key annual compliance deadlines for employer health plans?

Key annual deadlines include: January 31 (W-2 Box 12 Code DD reporting), March 1 (furnish 1095-C to employees), March 31 (electronic 1094-C/1095-C filing with IRS), July 31 (Form 5500 filing for calendar-year plans, or October 15 with extension), July 31 (PCORI fee payment via Form 720), December 31 (gag clause attestation to CMS), and December 27 (RxDC prescription drug reporting to CMS). Self-funded plans have additional deadlines for COBRA notices and SPD distribution.

When must employers distribute Summary Plan Descriptions (SPDs)?

New participants must receive the SPD within 90 days of becoming covered by the plan. New plans must distribute the SPD within 120 days of the plan becoming subject to ERISA. Updated SPDs must be distributed every 5 years if the plan has been amended, or every 10 years if there have been no amendments. A Summary of Material Modifications (SMM) must be distributed within 210 days after the end of the plan year in which a material modification was made.

What is the Form 5500 filing deadline for health plans?

Form 5500 is due 7 months after the end of the plan year — July 31 for calendar-year plans. A 2.5-month extension is available by filing Form 5558 before the original due date, extending the deadline to October 15. Health plans with fewer than 100 participants at the beginning of the plan year are generally exempt from Form 5500 filing. Self-funded plans with 100+ participants must file Form 5500 with Schedule A or J.

What is the PCORI fee and when is it due?

The PCORI fee (Patient-Centered Outcomes Research Institute fee) is an annual fee paid by self-funded health plan sponsors to fund comparative effectiveness research. The fee is $3.22 per covered life for plan years ending in 2025 (indexed annually). It is reported and paid on IRS Form 720 by July 31 of the calendar year following the last day of the plan year. Fully insured plans have the carrier pay the PCORI fee; self-funded employers pay it directly.

What notices must employers provide to health plan participants annually?

Annual required notices include: Summary of Benefits and Coverage (SBC) at open enrollment, Women's Health and Cancer Rights Act notice, HIPAA special enrollment rights notice, CHIP/Medicaid premium assistance notice (if applicable), Medicare Part D creditable coverage notice (for plans with Medicare-eligible participants), and the Children's Health Insurance Program (CHIP) notice. Many of these can be distributed electronically if participants have regular computer access at work.

Calendar

Employer Healthcare Compliance Calendar

Missing a compliance deadline can result in significant penalties. Use this calendar to track key employer healthcare compliance obligations throughout the year.

January

W-2 reporting of employer-sponsored health coverage (Box 12, Code DD)

ACA 1095-C/1094-C filing deadline (paper): March 1

Review prior year compliance for any issues

February–March

ACA 1095-C distribution to employees: March 3

ACA 1094-C/1095-C electronic filing deadline: April 1

PCORI fee due July 31 (for calendar year plans)

April–June

PCORI fee payment due July 31

Review plan document for any needed amendments

Prepare for open enrollment — review plan design and vendor performance

July–September

PCORI fee due July 31

Begin open enrollment preparation

Review stop-loss renewal strategy (if calendar year plan)

Annual CHIP notice distribution

October–November

Open enrollment period (typically)

Medicare Part D creditable coverage notices (October 15)

Summary of Benefits and Coverage (SBC) distribution

Annual HIPAA privacy notice (if required by plan)

December

Finalize plan changes for new plan year

Ensure all required notices have been distributed

Review compliance checklist for upcoming year

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