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 |
|---|---|---|
| 1/1/2025 | IRS benefit limits for 2025 take effect | Ensure benefit and payroll systems are properly updated to reflect adjusted limits Confirm plan’s out-of-pocket limit for essential health benefits doesn’t exceed ACA limits for plan year beginning in 2025 ($9,200/$18,400) FSA maximum contribution limit for 2025 plan years is $3,300 ($660 carryover limit) Excepted Benefit HRA maximum for 2025 plan years is $2,150 |
| 1/1/2025 | HIPAA Policies and Procedures | Policies and procedures should be updated to reflect the enhanced privacy considerations associated with reproductive rights. Employers must also begin utilization of their plan’s individually adopted consent for authorization of release of certain reproductive information. |
| 1/1/2025 | First-dollar preventive care coverage (applies to non-grandfathered plans) | Confirm health plan covers the latest recommended preventive care services without cost sharing (see https://www.healthcare.gov/coverage/preventive-care-benefits/) for the latest recommended services |
| 1/1/2025 | San Francisco Health Care Security Ordinance (SFHCSO) changes for 2025: Health care expenditure rates increase to $3.85/hour (businesses with > 100 employees) and $2.56/hour (businesses with 20-99 employees) Updated notice for posting at workplace Revocable health care expenditures no longer permitted | Employers subject to the SFHCSO must comply by making required health care expenditure payments on behalf of covered employees (generally those employed >90 days and working at least 8 hours per week in the City) |
| 1/1/2025 | Employer Mandate (“play or pay”) | Confirm applicable large employer (ALE) status for 2025 ALEs average at least 50 full- time employees in prior year (2024) Determine full-time employee status for 2025 using lookback measurement method or monthly measurement period, as applicable Confirm compliance with guidance on cash-out arrangements and wellness incentives Determine affordability (9.02% of household income) using W-2, rate of pay, or federal poverty level safe harbor and minimum value thresholds (60%) for 2025 4980H(a) monthly penalty amount = $2,900/12 x Full-time employees (less first 30) 4980H (b) monthly penalty amount =$4,350/12 x FT employees receiving a subsidy Confirm plan documents/ SPDs and employee handbooks have been updated to reflect any changes made to eligibility criteria |
| 1/1/2025 | Grandfathered Health Plans (GF) | Confirm plan’s status for 2025: If plan lost status, confirm that plan has adopted all additional patient rights and benefits required by non-GF plans If plan-maintained GF status, continue to provide Notice of Grandfathered Status in plan materials provided to participants |
| 1/1/2025 | Employers with 10 or more Information filings (in the aggregate) are required to file certain information returns with the IRS electronically, including those required to comply with the employer shared responsibility provisions under the Affordable Care Act | Employers who are not currently set up for electronic filing should take steps to do so soon, whether on their own or through a third- party. Reporting entities in a position to perform their own electronic reporting can review the IRS’ ACA Information Returns (AIR) Program webpage Read here for more information on the electronic filing process and the AIR System, as well as IRS Publications 5164 and 5165 |
| 1/31/2025 | W-2 Reporting of Employer Sponsored Benefits (Transitional relief for employers with less than 250 W-2s until further guidance) | Employers that filed 250 or more IRS Forms W-2 for the prior calendar year must include the aggregate cost of employer-sponsored health plan coverage on employees’ Forms W-2.Include the aggregate cost of medical insurance (generally not dental, vision, disability benefits or FSA unless employer contributions made) Employers must file Forms W-2 with the Social Security Administration and furnish Forms W-2 to employees Work with payroll vendor to ensure compliance |
| 1/31/2025 | Massachusetts Form 1099-HC due to employees who are state residents to assist them in filing their tax returns; report listing of all Form 1099-HCs issued due to State. For further information visit https://www.mass.gov/service- details/health-care-reform-for-employers | Responsibility of health insurer and/or employer (if self-funded) Confirm that the health plan meets the definition of creditable coverage under Massachusetts state law requirements Work with health insurer to confirm party responsibility for providing Form and ensure timely distribution |
| 1/31/2025 | IRS Forms 1095-C due to employees of self-insured medical plans to comply with CA Individual Mandate | Self-insured plan sponsors comply by providing Form 1095-C statements to all covered employees (and non-employees), regardless of FT status, including completing Part III of the Form 1095-C |
| 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), 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 |
To see the full 2025 year of Compliance Deadlines, click on this LINK.
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