Employer Benefits Compliance Checklist — ACA, ERISA, HIPAA & COBRA
Employer Benefits Compliance Checklist
Track your compliance status across ACA, ERISA, HIPAA, COBRA, Mental Health Parity, Transparency in Coverage, and required annual notices.
Total Items
22
compliance requirements
Completed
0
0% complete
Critical Open
11
require immediate attention
High Priority Open
8
should be addressed soon
Applicable Large Employers must file annual ACA reporting with the IRS and furnish 1095-C to employees.
Deadline: March 31 (electronic)
Verify that minimum essential coverage is offered to at least 95% of full-time employees and dependents.
Deadline: Ongoing
Confirm plan meets 60% minimum value threshold and affordability safe harbor for 2026.
Deadline: Annual renewal
Distribute SBC to all enrollees and applicants at open enrollment and upon request.
Deadline: Open enrollment
Ensure SPD is up-to-date and distributed to all plan participants within 90 days of enrollment.
Deadline: Within 90 days of enrollment
File Form 5500 for plans with 100+ participants. Plans with fewer than 100 may qualify for simplified filing.
Deadline: July 31 (or Oct 15 with extension)
Maintain a wrap plan document that incorporates all welfare benefit plans into a single ERISA plan.
Deadline: Ongoing
Document prudent process for plan decisions, vendor selection, and fee review.
Deadline: Ongoing
Ensure proper separation between health plan PHI and general HR functions. Business Associate Agreements in place.
Deadline: Ongoing
Distribute NPP to all plan participants at enrollment and upon material revision.
Deadline: Annual / at enrollment
All employees with access to PHI must complete HIPAA privacy and security training.
Deadline: Annual
Provide general COBRA notice to new enrollees within 90 days of coverage start.
Deadline: Within 90 days of enrollment
Administer timely COBRA election notices following qualifying events.
Deadline: 14 days of qualifying event
Document that mental health/substance use disorder benefits are not more restrictive than medical/surgical benefits.
Deadline: Available upon request
Perform and document NQTL analysis for prior authorization, step therapy, and network adequacy.
Deadline: Ongoing
Ensure in-network rates and out-of-network allowed amounts are published in required MRF format.
Deadline: Ongoing
Provide internet-based price comparison tool for 500 shoppable services.
Deadline: Ongoing
Ensure wellness incentives comply with HIPAA nondiscrimination rules and ADA reasonable accommodation requirements.
Deadline: Annual review
Confirm wellness program does not request genetic information or family medical history in exchange for incentives.
Deadline: Annual review
Provide annual WHCRA notice to plan participants.
Deadline: Annual
Include NMHPA disclosure in plan documents and SPD.
Deadline: At enrollment
Provide annual notice to Medicare-eligible participants regarding prescription drug coverage credibility.
Deadline: Before Oct 15 annually
Is your plan fully compliant?
The 126-Point Benefits Benchmark includes a comprehensive compliance review — ERISA, ACA, HIPAA, COBRA, Mental Health Parity, and Transparency in Coverage — with specific findings and remediation guidance.
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