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Compliance Corner: Important Deadline Reminders

As a reminder, there are two important deadlines for employer-sponsored group health plans due March 1, 2019 and March 4, 2019. 

Due March 1, 2019 - Medicare Part D Online Disclosure to CMS For Calendar Year Plans

Employers who sponsor group health plans that provide prescription drug coverage must complete an online disclosure to CMS (Centers for Medicare & Medicaid Services) certifying whether their prescription drug coverage is creditable or non-creditable.

The disclosure must be made to CMS on an annual basis or whenever a change occurs to the group health plan’s prescription drug coverage that affects the creditability of the plan. The Medicare Part D disclosure notice must be made during the instances below:

  • Within 60 days after the beginning of the plan year (renewal, contract year, etc.) for which the employer is providing the disclosure to CMS
  • For group health plans that begin January 1st disclosure must be made by March 1st (For example, plans beginning January 1, 2019 must disclose to CMS by March 1, 2019)
  • For non-calendar year health plans, disclosure is due within 60 days from the beginning of the plan year (For example, plans beginning May 1st must disclose to CMS by July 1st)
  • Within 30 days after the termination of a plan’s prescription drug coverage; and
  • Within 30 days after any change in the plan’s creditable coverage status

For more information, click here

Deadlines for 2018 ACA Reporting 

The IRS extended the furnishing deadline for health insurers, self-insuring employers, other health coverage providers and applicable large employers to provide Forms 1095-B or 1095-C to employees or covered individuals. They now have until March 4, 2019. This is an automatic extension for all reporting entities; therefore, the IRS will not grant any additional extensions of time to furnish the required forms 1095-B or 1095-C to employees or covered individuals.

IRS Filing Deadlines

However, the due dates for filing returns (Forms 1094-B, 1095-B, 1094-C or 1095-C) with the IRS for 2018 have not been extended. The due dates to file returns with the IRS are below:

  • February 28, 2019 if filing paper forms
  • April 1, 2019 if filing electronically (since March 31, 2019 is a Sunday) electronic filing is required if filing more than 250 Forms 1095-C for 2018

Because the due dates for filing forms with the IRS are unchanged, extensions for filing these returns are still available under the traditional rules by submitting a Form 8809, including the rules for hardship conditions.

Employers who fail to meet the deadlines for furnishing and filing the forms are subject to penalties; however, even if employers or other providers miss the deadline efforts should continue to be made to furnish and file the forms to potentially mitigate penalties.

For more information, click here

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