Annual Notices Calendar
| Notice | Deadline | Penalty for Failure |
|---|---|---|
| Medicare Part D creditable coverage | October 15 (before Medicare open enrollment) | $110/day |
| CHIP notice | Before each plan year | $110/day |
| Women's Health and Cancer Rights Act | At enrollment and annually | $110/day |
| Newborns' and Mothers' Health Protection Act | At enrollment | $110/day |
| Summary of Benefits and Coverage (SBC) | At enrollment and annually | $1,000/failure |
| Summary Annual Report (SAR) | 9 months after plan year end | $110/day |
| HIPAA privacy notice | At enrollment and every 3 years | Variable |
Electronic Distribution
Electronic distribution of required notices is permitted under DOL safe harbor rules. For employees with work-related computer access, notices can be distributed electronically without prior consent. For employees without work-related computer access, prior consent is required. The DOL's 2020 electronic disclosure safe harbor provides an additional option for pension plan disclosures.
Building the Compliance Calendar
Pro Tip
Build an annual notices compliance calendar that tracks all required notices, deadlines, distribution methods, and completion status. Assign responsibility for each notice to a specific person. Review the calendar quarterly to ensure all notices are on track. A missed notice can result in significant penalties — and is easily preventable with a systematic compliance calendar.