The start of a new year is a time of great promise for many businesses. The focus shifts from reflecting on the previous year to looking ahead to achieve new goals and objectives.
It is also a time when human resources departments must carefully plan the year from a compliance standpoint, considering any new or changing regulations. 2024 compliance checklists can be a helpful tool for ensuring compliance throughout the year.
Here is a month-by-month look at the major points human resources experts must consider in 2024.
31: This is the deadline for employers who filed 250 or more W2s during the previous calendar year. Those employers must report the costs of their healthcare plans to the Social Security Administration and provide forms to their employees. Businesses with fewer than 250 employees are not subject to this requirement.
24: Self-insured employers must file Forms 1094-C and 1095-C regardless of their size by this date, while non-applicable large employers who sponsor a self-insured group health plan must file Forms 1094-B and 1095-B by this date. Employers who need more time to prepare these documents can use Form 8809 to request a 30-day extension.
1: All employers must submit Medicare Part D Online Disclosure Forms by this date; they must be sent electronically through the Centers for Medicare and Medicaid Services (CMS) website. The form indicates whether the employer’s prescription drug coverage is considered creditable.
This is also the deadline for the administrators of Multiple Employer Welfare Arrangements offering medical benefits to file Form M-1 electronically with the Department of Labor. Employers can file for a 60-day automatic extension if more time is needed.
4: Forms 1095-B and 1095-C must be provided to employees by this date. Fully insured and self-insured applicable large employers (ALEs) must supply form 1095-C to employees.
Employers can comply with this requirement by posting a clear and conspicuous notice on their website explaining that non-full-time employees enrolled in their self-insured plan can obtain a copy of this statement by request; they must supply it within 30 days of any requests they receive. This also applies to self-insured non-ALEs.
1: Non-ALEs that have self-insured plans must file Forms 1094-B and 1095-B. ALEs with self-insured or fully insured plans must file forms 1094-C and 1095-C.
1: This is the deadline for all plans and issuers to file their yearly RxDC report.
31: All self-insured plans must complete Form 720 and pay an annual fee for the quarter that ended on June 30 by this date.
This is also the deadline for plans not qualifying for small plan exemptions to file their Form 5500 electronically. Form 5558 can be filed once to obtain an automatic 2.5-month extension. Fully insured, unfunded, and combination small plans with fewer than 100 participants are typically exempt from this requirement.
1: Broker compensation disclosures must be submitted by covered providers by this date if their direct and indirect compensation is expected to be $1,000 or more.
30: All plans required to file Form 5500 must give participants a Summary Annual Report by this date.
1: All employers offering Qualified Small Employer Health Reimbursement Arrangements must notify eligible employees by this date. This deadline also applies to employers who offer individual coverage health reimbursement arrangements.
15: All eligible employees for Medicare Part D must be given an official notification informing them whether the plan’s prescription drug coverage is creditable by this date.
31: All covered entities whose protected health information was subject to an unsecured breach must submit a HIPAA breach report under certain circumstances by this date.
1: All employers who offer Cafeteria Plans must pass specific nondiscrimination testing by this date, depending on their circumstances.
15: This is the extended deadline for employers who must file Form 5500 to give participants a summary of their Form 5500 data.
31: Issuers and plans required to file a gag clause prohibition compliance attestation must do so by the end of the year.
Certain notices must be supplied to employees annually, depending on the circumstances of the organization and its benefits plan. These include the Notice of Patient Protections Against Surprise Billing, Summary Plan Description, HIPAA and ADA Wellness Notices, Grandfathered Plan Status Notice, and the Children’s Health Insurance Program Notice.
Other notices must be supplied upon hiring, such as the COBRA rights notice, HIPAA Notice of Privacy Practices, and HIPAA Special Enrollment Notice.
Ensure Compliance With Help from the Experienced Benefits Consultants
This checklist is not an exhaustive list of deadlines. For customized 2024 compliance checklists and requirements, businesses should consult with benefits experts to determine which points apply to their circumstances.