Important Deadlines and Reminders for 2019

DOL Releases New Model Employer CHIP Notice
Notice Information Current as of January 31, 2019

The U.S. Department of Labor (DOL) has released a new model Employer CHIP Notice with information current as of January 31, 2019. As a reminder, employers that provide health insurance coverage in states with premium assistance through Medicaid or CHIP must provide employees with a CHIP Notice annually before the start of each plan year (NY is not one of these states). An employer can choose to provide the notice on its own or concurrent with the furnishing of:

Materials notifying the employee of health plan eligibility;
Materials provided to the employee in connection with an open season or election process conducted under the plan; or
The summary plan description (SPD).

For information on additional notice requirements, download our free Benefits Notices by Company Size.

Reminder: Post OSHA Form 300A Starting Feb. 1

Form Must Remain Posted Through April

Employers subject to OSHA’s record-keeping requirements are reminded to post their 2018 OSHA Form 300A from February 1–April 30, 2019. This form—which must be posted even if no work-related injuries or illnesses occurred during 2018—should be displayed in a common area where notices to employees are usually posted.

You can download a .pdf copy of the OSHA 300A form here.

Reminder: Medicare Part D Notices Are Due to CMS by March 1

Employers that provide drug benefits must notify the Centers for Medicare & Medicaid Services

Each year, group health plan sponsors that provide prescription drug coverage to individuals eligible for Medicare Part D must electronically disclose to the Centers for Medicare & Medicaid Services (CMS) whether that coverage is “creditable” or “noncreditable.” The disclosure obligation applies to all plan sponsors that provide prescription drug coverage, even those that offer prescription drug coverage only to active employees and not to retirees. Calendar-year plans must submit this year’s disclosure to CMS by March 1, 2019.

Plan sponsors generally must disclose creditable coverage status to CMS within 60 days after the beginning of each plan year. Disclosure is made online using the creditable coverage Disclosure to CMS Form available on the CMS website.

OSHA Form 300A Electronic Submission Deadline is March 2

Many Large and High-Risk Industry Employers Subject to the Requirement

Employers are reminded that they may be required to electronically submit information from their 2018 OSHA Forms 300A to OSHA by March 2, 2019. By that date, the following establishments, if currently required to comply with OSHA’s recordkeeping requirements, must electronically submit this information through OSHA’s Injury Tracking Application (ITA):

Establishments with 250 or more employees in industries covered by OSHA’s recordkeeping requirements; and
Establishments with 20-249 employees in certain high-risk industries.

Click here to access the Injury Tracking Application.

Reminder: NYS Sexual Harassment Training Due October 9th, 2019

All employers must conduct annual sexual harassment training

New York State has released finalized versions of its model sexual harassment prevention training program and model sexual harassment prevention policy. As a reminder, within 12 months of October 9, 2018, and annually thereafter, all New York employers must provide training to all employees using either the state’s model training program or one that equals or exceeds the state program. Additionally, starting October 9, 2018, all New York employers must adopt either the state’s model sexual harassment prevention policy or one that equals or exceeds the standards of the state policy, and provide it to employees in writing.

Please click here to view the model training program and other resources.