New Year, New Benefits: 9 Annual Reporting Milestones

Angela Surra

Angela Surra

The only thing better than executing a successful benefits strategy is bragging about it to governing agencies—also known as annual reporting! In the dynamic landscape of employee benefits, strategic planning goes hand in hand with meticulous annual reporting toward shaping a positive and compliant workplace.

By adopting a proactive approach, organizations can attract and retain top talent, ensure regulatory compliance, and maintain transparency in benefits administration. And it doesn’t get much more proactive than at the start of the year! With that in mind, here is a quick guide to your top nine benefits compliance annual reporting responsibilities to mark on your calendar right now.

1. Compile and distribute ACA forms.

Under the Affordable Care Act (ACA), applicable large employers (ALEs) those with 50 or more full-time and full-time equivalent employees) and any size employer sponsoring a self-funded medical plan are required to report information about the health coverage they offer to their

employees. ACA reporting helps the IRS monitor compliance with employer –hared responsibility provisions. This reporting is done using IRS Forms 1094-C and 1095-C.

Save the date: ALEs must provide employees with Form 1095-C generally by March 1, which outlines the coverage offered and the months of coverage, and then must electronically file the forms to the IRS around April 1.

2. Submit RxDC program information.

The Prescription Drug Data Collection (RxDC) program requires employers that offer

prescription drug coverage to submit information through the Centers for Medicare and Medicaid Services (CMS) portal that helps the agency determine whether the employer’s prescription drug coverage is creditable. Fully insured plans should confirm whether their carrier is handling the submission, and self-funded plans should check whether their third party administrator is submitting on their behalf.

Save the date: The deadline for RxDC submission typically falls on June 1 each year.

3. File and pay PCORI fees.

Also established under the ACA, the Patient-Centered Outcomes Research Institute (PCORI) fee funds research that evaluates and compares clinical effectiveness and health outcomes, risks and benefits of medical treatments, procedures and drugs. Employers that offer level funded or self-funded health plans are responsible for filing Form 720 and paying the PCORI fee. This fee is based on the average number of covered lives under the plan and must be paid annually.

Save the date: The deadline for PCORI filing is typically July 31.

4. File Form 5500.

Many businesses that offer benefits subject to the Employee Retirement Income

Security Act (ERISA) must file Form 5500, which provides information about the

financial condition, investments, and operations of a plan. This filing requirement applies to various types of plans, including health and welfare plans, pension plans, and 401(k) plans.

Save the date: ERISA-covered calendar year plans must file Form 5500 by July 31.

5. Provide SARs.

Employers that file Form 5500 must provide a Summary Annual Report (SAR) to participants and beneficiaries. The SAR is a narrative of Form 5500 summarizing the financial information and operations of the plan.

Save the date: The yearly SAR distribution deadline for calendar year plans is September 30.

6. Issue MLR rebates.

Under the ACA, health insurance issuers are required to spend a certain percentage of their premium revenue on actual benefits; this percentage is known under the law as the medical loss ratio (MLR). Issuers that fail to meet the MLR requirements must provide rebates (i.e., refund) back to the plan. Employers that receive MLR rebates must distribute them to employees promptly and according to ACA guidelines.

Save the date: MLR rebates are typically issued in August or September.

7. Provide QSEHRA notices.

Organizations that offer qualified small employer health reimbursement arrangements (QSEHRAs) must provide a notice to eligible employees informing them about QSEHRA availability, and providing information about the reimbursement limits and requirements.

Save the date: The annual deadline for delivering the QSEHRA notice is October 1.

8. Provide Medicare Part D notices.

Employers offering prescription drug coverage to Medicare-eligible individuals must provide annual notices regarding the creditability of their coverage. Creditable coverage notice informs individuals whether their coverage is expected to pay, on average, as much as the standard Medicare Part D prescription drug coverage.

Save the date: The deadline for providing Medicare Part D notices to participants is on or before October 15 each year. Typically, health plans must disclose to the Centers for Medicare and Medicaid Services (CMS) whether prescription drug coverage is creditable by March 1.

9. Conduct nondiscrimination testing.

Most organizations with cafeteria plans that allow employees to withhold pre-tax dollars for qualified

benefits—including health flexible spending accounts and dependent care flexible spending accounts —must conduct nondiscrimination testing to ensure fairness in benefits distribution. This testing affirms that plans do not discriminate against rank and file employees, plus helps businesses identify any potential issues and take corrective actions.

Save the date: Employers are required to annually complete and retain the results of their nondiscrimination testing.. Generally, testing occurs toward the end of the plan year.

Through thoughtful strategic planning and timely annual reporting, you can ensure your employee benefits programs are not only successful and compliant, but also transparent and satisfying for your diverse and thriving workforce.

Author: Angela Surra
About
Angela Surra, CIC, CISR, SHRM-CP is the Principal Benefits Expert at Mineral