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 |
|---|---|---|
| 11/15/2024 (or 15th day of the 11th month after end of the plan year) | Form 990 (or 990-EZ), if second 3- month extension was obtained | Applies to VEBAs only. |
| 12/16/2024 | Health Insurance Responsibility Disclosure (“HIRD”) form due to Massachusetts Department of Revenue: For more information visit this link. | 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 11/15/2024-12/15/2024. |
| 12/16/2024 (or 2 months after close of extension period for filing Form 5500) | Summary Annual Report, if extension was filed (calendar year plans) | Plan Sponsors that file Forms 5500 must provide to covered participants. |
| 12/31/2024 | Update/amend documents for 2024 plan year | Provide updated SBCs in connection with plan’s 2025 open enrollment period. Amend cafeteria plan to reflect any changes made in 2024. Amend/restate wrap document and SPD as necessary. |
| 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 505 for VEBAs. Code Section 129 for Dependent Care FSAs. Code Section 127 for Educational Assistance. Code Section 137 for Adoption Assistance. |
| 12/31/2024 | Attestation of compliance with prohibition on gag clauses | Ensure any contracts with third party administrators (“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 2024 year of Compliance Deadlines, click on this LINK.
For more information
We’re ready when you are. Get in touch and a friendly, knowledgeable Baldwin advisor is prepared to discuss your business or individual needs, ask a few questions to get the full picture, and make a plan to follow up.
This document is intended for general information purposes only and should not be construed as advice or opinions on any specific facts or circumstances. The content of this document is made available on an “as is” basis, without warranty of any kind. The Baldwin Insurance Group Holdings, LLC (“The Baldwin Group”), its affiliates, and subsidiaries do not guarantee that this information is, or can be relied on for, compliance with any law or regulation, assurance against preventable losses, or freedom from legal liability. This publication is not intended to be legal, underwriting, or any other type of professional advice. The Baldwin Group does not guarantee any particular outcome and makes no commitment to update any information herein or remove any items that are no longer accurate or complete. Furthermore, The Baldwin Group does not assume any liability to any person or organization for loss or damage caused by or resulting from any reliance placed on that content. Persons requiring advice should always consult an independent adviser.
The Baldwin Group offers insurance services through one or more of its insurance licensed entities. Each of the entities may be known by one or more of the logos displayed; all insurance commerce is only conducted through The Baldwin Group insurance licensed entities. This material is not an offer to sell insurance.
