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 |
|
8/1/2025 through 10/31/2025 (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 for using the rebate. Any rebate amount that qualifies as a plan asset under ERISA must be used for the exclusive benefit of the plan’s participants and beneficiaries. If received, the rebate amounts attributable to plan assets generally must be distributed pro-rata to the members in either premium credits or other benefits within 90 days of receipt. § Plan sponsors should document how rebate was disbursed to the plan’s participants. |
|
9/30/2025 |
Summary Annual Report
9 months after end of plan year; additional 2 months permitted if Form 5558 extension filed) |
§ Plan Sponsors that file Form 5500 must provide to covered participants a summary of the information in the Form 5500. |
|
10/14/2025 |
Notice of Medicare Part D Creditable/ Non-Creditable Coverage (Medicare Part D Notice) |
§ Provide to Medicare Part D-eligible participants (employee or dependent who is over age 65 or permanently disabled) annually § Providing Notice during open enrollment to all participants is generally adequate. § Model disclosure notices are available on CMS’ website. |
|
10/15/2025
|
Form 5500, if extension Form 5558 was filed (calendar year plans) 9 ½ months after end of the plan year+ extension period |
§ All health and welfare plans with 100+ participants that are subject to ERISA are required to report unless an exemption applies § Small health plans (fewer than 100 participants) that are fully insured, unfunded or a combination of insured/unfunded are generally exempt from the Form 5500 filing requirement. |
To see the 2025 Compliance Deadlines, click on this link.
For more information
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