Navigating Health Plan Compliance in 2024: Key Deadlines for Employers

As we march into 2024, employers are faced with a series of critical compliance deadlines related to their group health plans. Adhering to these dates is not just about staying organized; it’s a legal mandate that can have significant implications for your business and employees. This blog post will walk you through the key compliance deadlines for 2024 and offer insights into the importance of each requirement.

Understanding Your Plan Year

Before we dive into the specifics, it’s crucial to understand what defines a “plan year” as it directly influences your compliance timeline. A plan year could align with the calendar year, your company’s fiscal year, or the policy year for insured plans. Knowing your plan year is the first step to compliance success.

Important Compliance Deadlines for 2024

January

• W-2 Reporting (Jan. 31, 2024): For employers who filed 250 or more W-2 forms in the previous year, the aggregate cost of employer-sponsored health coverage must be reported on employees’ W-2 forms. This deadline is crucial for ensuring transparency in health plan costs.

February

• ACA Reporting (Feb. 28, 2024): Applicable Large Employers (ALEs) are required to file Forms 1094-C and 1095-C by this date for paper filings, with electronic filings due by April 1, 2024. Note that from 2024, most employers will need to file electronically, with paper filing reserved for smaller employers meeting specific criteria.

March

• ACA Forms to Employees (March 1, 2024): ALEs must furnish Form 1095-C to employees by this date. Similarly, non-ALEs with self-insured plans must furnish Form 1095-B.

April

• Electronic Filing of ACA Forms (April 1, 2024): If you’re an ALE, mark this as the deadline for electronically filing Forms 1094-C and 1095-C.

June

• Prescription Drug Data Collection Report (June 1, 2024): Employers need to submit this report, and it’s generally prepared by third parties like TPAs or PBMs.

July

• PCORI Fees and Form 5500 (July 31, 2024): Employers with self-insured plans must report and pay their PCORI fees, and those covered by ERISA must file their Form 5500.

September

• MLR Rebates and SAR (Sept. 30, 2024): Watch for possible MLR rebates from insurers and provide the Summary Annual Report to participants if required.

October

• Medicare Part D Notices (Oct. 14, 2024): Inform eligible individuals whether their drug coverage is creditable.

December

• Gag Clause Attestation (Dec. 31, 2024): Submit your compliance attestation through the CMS website.

Annual Notices to Keep in Mind

Throughout the year, there are also a series of notices that need to be provided to employees, including the Summary of Benefits and Coverage (SBC), CHIP notices, and others as mandated by ERISA, COBRA, and the ACA. These documents are vital for keeping employees informed about their health benefits and ensuring that plans comply with federal requirements.

Conclusion

As an employer, staying ahead of these 2024 health plan compliance deadlines is non-negotiable. It’s about protecting your business from penalties and your employees from uncertainty. Be proactive, mark your calendars, and consult with legal counsel to ensure you’re not just compliant, but also providing the best possible benefits for your team.

For detailed guidance and assistance, reach out to your broker at Corporate Coverage today. We’re here to help you navigate the complexities of health plan compliance.