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 Employers must comply with numerous reporting and
disclosure requirements throughout the year in connection with
their group health plans.
Listed below are upcoming important compliance deadlines for
employer-sponsored group health plans, organized chronologically.
For these requirements, the information provided herein shows the
deadlines that apply to calendar year plans. For non-calendar
year plans, these deadlines will need to be adjusted to reflect
each plan’s specific plan year.
January 2020
Employers that filed 250 or more IRS Forms W-2 for the prior
calendar year must file Forms W-2 with the Social Security Administration
and furnish Forms W-2 to employees by Jan. 31 of each year,
unless an extension applies.
February
2020
ALEs that sponsor fully or self-insured health plans are required
to report information about the coverage to the IRS each year,
using IRS Forms 1094-C and 1095-C.
Employers that sponsor self-insured plans and are not ALEs use
IRS Forms 1094-B and 1095-B to
meet these reporting obligations. The deadline for filing paper
versions of the forms is Feb. 28, 2020. The deadline for
electronic filing is March 31, 2020.
March 2020
Group health plan sponsors that provide prescription drug
coverage to Medicare Part D-eligible individuals must disclose to
the Centers for Medicare & Medicaid Services (CMS) whether
prescription drug coverage is creditable or non-creditable within
60 days after the beginning of the plan year. For calendar year
plans, the deadline is March 1, 2020.
ALEs that sponsor fully or self-insured health plans to report
information about the coverage to covered employees each year,
using IRS Form 1095-C.
Employers that are not ALEs use IRS Form 1095-B to
provide this information. The IRS recently extended the deadline
for furnishing 2019 employee statements, from Jan. 31, 2020, to
March 2, 2020.
The electronic filing deadline for Code Sections 6055 and 6056
reporting is March 31, 2020. ALEs that sponsor fully or
self-insured health plans are required to report information
about the coverage to the IRS each year, using IRS Forms 1094-C and 1095-C.
Employers that sponsor self-insured plans and are not ALEs use
IRS Forms 1094-B and 1095-B to
meet these reporting obligations.
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