Missing a compliance deadline is not just a harmless administrative mistake. It can lead to penalties, employee confusion, and hours spent correcting errors that could have been easily prevented. For HR managers and benefits administrators who are already contending with multiple responsibilities, staying ahead of date-sensitive tasks requires a careful balance.
Benefits administration involves meeting dozens of federal deadlines throughout the year, and each has its own set of requirements and consequences. Although there is no way to eliminate these obligations, you can build a system that keeps your business compliant without taking on the constant stress of last-minute scrambling.
Why January Sets the Tone for Your Entire Year
Start the year strong by handling W-2 reporting correctly. By January 31, you’ll need to file W-2s that include specific benefits-related information. In addition, employers who filed at least 250 W-2s in the previous year are required to report the cost of coverage in Box 12 using Code DD. This encompasses employer and employee contributions.
Don’t overlook HSA reporting, either. All employer contributions to Health Savings Accounts need to appear in Box 12 with Code W. If your business offers dependent care benefits, those amounts should be listed in Box 10, with amounts over $5,000 also included in Box 1. Getting these details right in January can help to prevent issues when employees file their taxes in the spring.
March is Compliance Crunch Time
March brings a cluster of deadlines that cannot be overlooked. By March 1, employers who sponsor prescription drug plans must report their creditable coverage status to CMS within 60 days of the plan year’s start for calendar-year plans. This same date is also the deadline for HIPAA breach notifications to the Office for Civil Rights for incidents affecting fewer than 500 individuals.
The real heavy lifting involves Forms 1095-B and 1095-C. March 2 is the deadline to provide these forms to employees and covered individuals. All applicable Large Employers (those that have 50 or more full-time equivalents) must provide an offer of coverage information for the previous calendar year. Self-funded plans have their own 1095 requirements that cannot be ignored.
Then comes March 31, when those same forms, along with 1094-B and 1094-C, are due to the IRS. Miss this deadline, and your business could incur penalties that scale with the size of your workforce.
What Summer Deadlines Reveal About Your Plan Quality
The spring and summer months don’t mean you can take a break from compliance work. April 15 is the final day to make HSA contributions or correct previous-year contributions, which aligns with the tax filing deadline. This gives employers and individuals alike one last chance to maximize their tax-advantaged savings.
July brings three significant dates. July 28 marks the last day to issue a Summary of Material Modification for calendar year plans, which is required any time you make a material change to plan provisions. By July 31, you’ll need to file the PCORI fee for policy or plan years that ended in the previous year. This same date is also the Form 5500 deadline for calendar year plans.
When Fall Deadlines Demand Your Attention
September and October present another cluster of compliance deadlines. The Summary Annual Report, which summarizes Form 5500 data, is due on September 30 for calendar year plans. This is also the date when carriers must issue MLR rebates if they failed to meet minimum loss ratio requirements.
October 15 is another important date. First, it’s the deadline for distributing Medicare Part D creditable coverage notices to individuals. Keep in mind that employers can provide this notice at any time during the 12 months preceding this date, so incorporating it into your open enrollment communications makes strategic sense. In addition, this is the extended filing deadline for Form 5500 if you requested an extension.
How December Closes Your Compliance Loop
December wraps up the year with two final obligations. If your organization received any MLR rebates earlier in the year, December 29 will be your deadline to distribute the portion considered plan assets to all current participants. This 90-day window from receipt is firm, and missing it could make your business subject to ERISA trust requirements.
Finally, gag clause attestations are due on December 31. This requirement stems from the Consolidated Appropriations Act and applies to both employers and carriers.
Building Systems That Work Throughout the Year
Tracking these deadlines manually creates the type of unnecessary risk that can expose you to fines and other consequences. Modern employee benefits consulting leverages the latest technology to automate reminders, organize documentation, and secure that nothing falls through the cracks. The best systems won’t just remind you of deadlines; they’ll help you gather the needed information early, review submissions before filing, and maintain documentation for potential audits.
Consider how much time your team is currently spending tracking down information, verifying data, and rushing to meet deadlines, and imagine redirecting that energy toward strategic initiatives that actually improve your benefits program.
Are you ready to move from reactive to proactive benefits administration? The consultants at Business Benefits Group help businesses build compliance systems that work year-round, not just at deadline time. Reach out to us today to learn how we can streamline your benefits calendar and free your team to focus on what matters.