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 |
|
3/1/2025 |
Form M-1 Annual Reporting |
§ Applies to administrators of multiple employer welfare associations (MEWA) and entities claiming exemptions from certain federal law requirements. § File online at www.askebsa.dol.gov/mewa. |
|
3/2/2025 (or 60 days after beginning of plan year being reported to CMS) |
For calendar year plans, Medicare Part D disclosure to CMS regarding creditable coverage status of a group health plan’s prescription drug coverage |
§ Complete online disclosure form available at https://www.cms.gov/Medicare/Pre scription-Drug- Coverage/CreditableCoverage/CCDi sclosureForm.html. |
|
3/3/2025 |
Disclosure Statements to Employees under Internal Revenue Code Sections 6055 and 6056 |
§ All ALEs must provide a copy of Form 1095-C to their full-time (FT) employees to satisfy Code Section 6056’s requirements for the 2024 calendar year. § Self-funded employers must also provide Form 1095-C statements to all covered employees (and non- employees) if requested, regardless of FT status, to satisfy Code Section 6055’s requirements for the 2024 calendar year, including completing Part III of the Form 1095-C. § Statements can also be used to satisfy some state individual mandate disclosure requirements. |
|
3/31/2025 (if filing electronically) |
IRS Reporting Under Code Sections 6055 and 6056 |
§ Applicable large employers (ALEs) must file completed Forms 1094-C and 1095-C with IRS to comply with Code Section 6056. § To comply with Code Section 6055, carriers (fully insured plans) and employers that are not ALEs who sponsor self-insured health plans use Forms 1094-B and 1095-B to meet this reporting obligation. |
|
3/31/2025 |
Rhode Island individual mandate reporting due to Division of Taxation. For further information, see ADV_2022_29_individual_mandate_deadlin e.pdf (ri.gov) |
§ Employers (or TPA) of self-funded plans will file Forms 1095-C (Form 1094-B if self-insured sponsor is not an applicable large employer). § Insurance carriers will file Forms 1095-B on behalf of sponsors of fully insured plans. |
|
3/31/25 |
Reporting due to CA Franchise Tax Board to satisfy the California Mandate. For further information visit https://www.ftb.ca.gov/file/business/report-mec-info/technical-specifications.html |
§ Employers with self-funded plans must file Form 1095-C with state electronically or by mail (electronic filing required if 250 for more Forms 1095-Cs). § Insurance carriers will file Form 1095-Bs on behalf of fully insured plan sponsors. |
|
3/31/25 |
Reporting due to State of New Jersey to satisfy state’s shared responsibility requirement. For more information visit https://nj.gov/treasury/njhealthinsurancemandate/employers.shtml |
§ Employers of self-funded plans will file Forms 1095-C, NJ-1095, or Form 1095-B (if self-insured sponsor is not an applicable large employer). § Note: If using Form 1095- C, Parts I, II, and III all must be completed. § Insurance carriers will file Forms 1095-B on behalf of sponsors of fully insured plans. § Electronic filing only; paper filing will not be accepted. |
|
4/30/2025 |
District of Columbia Individual Mandate Reporting due. For further information, visit https://otr.cfo.dc.gov/sites/default/files/dc/ sites/otr/publication/attachments/FAQ%20r eporting%20SRP%20%288.6.19%29.pdf |
§ Applies to employers with at least one employee residing in Washington D.C. § Same information as filed with the IRS. § Must be filed within 30 days of IRS deadline for filing. |
|
4/30/2025 |
Annual San Francisco Health Care Security Ordinance (SFHCSO) Reporting |
§ Employers subject to the SFHCSO must file annual report for the 2024 calendar year with the Office of Labor Standards Enforcement. |
|
6/2/2025 |
Prescription Drug and Health Care Spending Reporting |
§ Annual report due to the federal government by employer-sponsored health plans and health insurance issuers to report information about prescription drugs and health care spending to the federal government for the 2024 reference year. This reporting process is referred to as the “prescription drug data collection” (“RxDC report”). § Most employers will rely on third parties, such as issuers, third-party administrators (TPAs) or pharmacy benefit managers (PBMs) to prepare and submit the RxDC report for their health plans.
|
|
7/29/2025
|
Summary of material modifications (SMMs)
Due 210 days after end of plan year |
§ Distribute SMMs regarding plan amendments adopted during previous year (2024 that reflect changes to the Summary Plan Description (SPD) unless revised SPD is distributed that contains the modifications). |
|
7/31/2025
|
Calendar year Form 5500 reporting deadline
Last day of the 7th month after end of plan year |
§ 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. § Employers may request a one-time extension of 2 ½ months by filing a Form 5558. |
|
7/31/2025 |
Patient Centered Outcomes Research Institute (PCORI) Fee due for plan years ending in 2024 |
§ Self-funded group health plans (including retiree plans and HRAs) must pay fee, based on enrollee count, using IRS Form 720. § For plan years ending after 1/1/24 and before 10/1/24 fee is $3.22 per enrollee. § For plan years ending on or after 10/1/24 and on or before 12/31/24 (includes most calendar year plans), the fee is $3.47. § If medical plan is not self-funded or level funded, the medical carrier will be responsible for paying this fee directly to the IRS. |
|
8/1/25 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 amount attributable to plan assets generally must be distributed pro-rata to the members in either premium credits or other benefit within 90 days of receipt. § Plan sponsors should document how rebate was used. |
|
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. |
|
12/15/2025 |
Health Insurance Responsibility Disclosure (HIRD) form due to Massachusetts Department of Revenue. For more information visit https://www.mass.gov/info-details/health- insurance-responsibility-disclosure-hird- faqs |
§ Applies to employers (regardless of location) with six or more employees within Massachusetts during the previous 12 months. § Filing is to be completed electronically from 11/15/2025- 12/15/2025. |
|
12/15/2025
|
Summary Annual Report, if extension was filed (calendar year plans) |
§ Plan Sponsors that file Form 5500 must provide to covered participants. |
|
12/23/2025 |
HIPAA Policies |
§ Review and update HIPAA policies and procedures regarding the use and disclosure of protected reproductive health information and provide training, where appropriate, to workforce members. |
|
12/31/2025 |
Update/amend documents for 2025 plan year |
§ Provide updated SBCs in connection with plan’s 2026 open enrollment period. § Amend wrap plan documents to reflect any changes made in 2025. |
|
12/31/2024 |
Nondiscrimination Testing |
§ Ensure applicable nondiscrimination testing is performed at least annually: § Code Section 105(h) for self-funded health plans, including Health Care FSAs and HRAs § Code Section 79 for Group Term Life Insurance § Code Section 125 for Cafeteria Plans Code Section 129 for Dependent Care FSAs Code § Section 127 for Educational Assistance Code § Section 137 for Adoption Assistance |
|
12/31/2025 |
Submit a Gag Clause Attestation for health plan |
§ Ensure any contracts with TPAs or other health plan service providers offering access to a network of providers do not violate the CAA’s prohibition of gag clauses. § Fully insured plan sponsors- confirm insurer will provide attestation. § Self-insured plans- consider entering into written agreements with their TPAs to provide the attestation, but the legal responsibility ultimately remains with the health plan. |
To see the full 2025 year of Compliance Deadlines, click on this LINK.
For more information
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