Employers must comply with numerous reporting and disclosure requirements in connection with their group health plans. Please note the following upcoming deadlines:
| Due Date | Topic | Requirement |
|---|---|---|
| 8/1-10/31/2024 (approximately) | Medical Loss Ratio (MLR) Rebates | Sponsors of insured health plans may receive rebates if their issuers did not meet their MLR for the respective reporting year. Rebates must be provided to plan sponsors by September 30 following the end of the MLR reporting year. Employers that receive rebates should consider their legal options prior to distributing any rebate dollars. Any rebate amount that qualifies as an ERISA plan asset must be utilized for the exclusive purpose of providing benefits to the plans’ participants and beneficiaries. Any rebate dollars that are received by the employer plan sponsor which are attributable to plan assets (e.g., participant contribution activities) must be distributed pro-rata to the underlying plan participants via one of several approved methodologies within 90-days of receipt; otherwise, these rebate dollars may trigger ERISA’s trust requirements. Plan sponsors should document how rebate was allocated and distributed |
| 8/15/2024 (or 15th day of 8th month following end of plan year if 1st extension was filed) | Form 990 (or 990-EZ), 2nd 3-month extension permitted by filing Form 8868 by this date | Applies to VEBAs |
| 9/30/2024 (or 9 months after end of plan year; additional 2 months permitted if Form 5558 extension filed) | Summary Annual Report | Plan Sponsors filing Form 5500 must provide a summary of the information in the Form 5500 to underlying participating population |
To see the full 2024 year of Compliance Deadlines, click here.
Lastly, our compliance calendar for 2024 is available here.
Be sure to sign up for our next webinar scheduled for August 28, 2024, on Mergers and Acquisitions. To register please click on this link.
If you missed the July 31 webinar on Medicare 101, you can find the recording here and the presentation deck at this link.
For more information
We’re ready when you are. Get in touch and a friendly, knowledgeable Baldwin advisor is prepared to discuss your business or individual needs, ask a few questions to get the full picture, and make a plan to follow up.
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