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 |
|
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 a fee, based on enrollee count, using IRS Form 720. § For plan years ending after 1/1/24 and before 10/1/24 the 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 the 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 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 the rebate was disbursed to the plan’s participants. |
To see the full 2025 year of Compliance Deadlines, click on this link.
For more information
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