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Baldwin Bulletin

Upcoming Compliance Deadlines

The Baldwin Group
Updated: July 11, 2024
2 minute read

Employers must comply with numerous reporting and disclosure requirements in connection with their group health plans.  Please note the following upcoming deadlines:

7/29/2024 (or 210 days after end of plan year)Summary of material modifications (SMMs)Distribute SMMs regarding plan amendments adopted during previous year (20230 that reflect changes to the Summary Plan Description (SPD) (unless revised SPD is distributed that contains the modifications)
7/31/2024 (or last day of the 7th month after end of plan year)Calendar year Form 5500 reporting deadline 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
7/31/2024Patient Centered Outcomes Research Institute (PCORI) Fee due for plan years ending in 2023Self-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 1/1/23 and before 10/1/23 fee is $3.00 per enrollee

For plan years ending on or after 10/1/23 and on or before 12/31/23 (includes most calendar year plans), fee amount per enrollee is $3.22.

If medical plan is not self-funded or level funded, the medical carrier will be responsible for paying this fee directly to the IRS
8/1-10/31/2024 (approximately)Medical Loss Ratio (MLR) RebatesSponsors 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

To see the full 2024 year of Compliance Deadlines, click here.

We have also included links to register for our next HIPAA training and educational webinar and attached our compliance calendar for the remainder of 2024.

Our forthcoming topic in our BRCC HIPAA Complete Educational Webinar Series on August 6, 2024, HIPAA 103/104: An Introduction to the Breach Notification and Enforcement Rules”. Please register here to attend.

—– Lastly, our webinar calendar for the remainder of 2024 is available here.

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