Annual ACA Compliance Calendar
| Deadline | Requirement | Responsible Party |
|---|---|---|
| January 31 | W-2 distribution (Box 12, Code DD for employer-sponsored coverage) | Employer |
| March 2 | 1095-C furnishing to employees | ALE (50+ FTEs) |
| March 31 | 1094-C and 1095-C filing with IRS (electronic) | ALE (50+ FTEs) |
| June 1 | RxDC reporting to CMS | Self-funded plans (or delegated to TPA/PBM) |
| July 31 | PCORI fee payment (Form 720) | Self-funded plans |
| October 15 | Medicare Part D creditable coverage notice | All plans with prescription drug coverage |
| December 31 | Gag clause attestation to CMS | All plans |
Building the Compliance Calendar
Build an annual ACA compliance calendar that tracks all deadlines, responsible parties, and completion status. Share the calendar with HR, legal, and finance teams. Review the calendar quarterly to ensure all deadlines are on track.
Delegation and Confirmation
Pro Tip
Many ACA compliance tasks can be delegated to carriers, TPAs, or PBMs — but the employer remains responsible. For each delegated task, obtain written confirmation of completion. A carrier that fails to file 1095-Cs on your behalf does not relieve the employer of the penalty — but the written confirmation creates a record for penalty abatement.