Welfare Benefit Plan ERISA News
October 2015

 
2016 Top 10 Compliance-Related Issues
for Employers
[1] Employer shared-responsibility (ESR) strategy.... [2] ESR reporting.... [3] Preventive care.... [4] Other ACA reporting and disclosure requirements.... [5] Midyear changes to cafeteria plan elections.... [6] ACA's out-of-pocket maximum.... [7] Same-sex marriages and domestic partnerships.... [8] Mental health parity.... [9] Wellness.... [10] Fixed-indemnity and supplemental health insurance." (Mercer)
Form 5500 Deadline Extensions Begin Next Year
"Beginning with calendar year 2016 returns to be filed in 2017, the automatically extended due date for the calendar-year return could be as late as November 15, 2017.... The automatic extensions that are linked to a sponsor's income tax filing deadline should likewise be subject to the extended limitation, and the filing deadline applicable to [a 'direct filing entity,' such as a master trust, pooled separate account, or certain other commingled vehicles,] should be extended by a month.... Until the effective time, however – including the next filing season, i.e., returns for plan years beginning in 2015, that will be filed for the most part during 2016 – the maximum extension available will remain at two and one-half months." (Ford & Harrison LLP)
Part D Medicare Creditable Coverage Notice
Due Oct. 15
The annual Creditable Coverage determination and disclosure deadline is Oct. 15 for your clients offering a prescription drug plan to Medicare-eligible individuals. This information is essential to an individual's decision whether to enroll in a Medicare Part D prescription drug plan. Insurance carriers are often helpful in determining whether an Rx plan is creditable, but not so in providing notice to affected individuals – that is the employer's responsibility. Although brokers and agents are not responsible for determining creditability and furnishing notice, their clients may expect to be apprised of their responsibility by their professional advisers. More information is available here. Here is a link to a model Creditable Coverage Disclosure Notice.
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© 2017 ERISAPros, LLC, All rights reserved. Information on ERISAPros' website, its newsletter, “News & Views,” and its blog, “ERISA Wonk,” is published as a general informational source. Information and articles are general in nature and are not intended to constitute legal or tax advice in any particular matter. Blog posts and comments reflect the personal views of their respective authors - not those of ERISAPros. Transmission of this information does not create an attorney-client relationship. ERISAPros, LLC is not a law firm and is not giving legal or tax advice. It does not warrant and is not responsible for errors or omissions in the content on its website or in its newsletters. ERISA is a complicated and confusing law. Summary Plan Descriptions (SPDs), Wrap Plan Documents, and Form 5500s require review and updating by qualified ERISA compliance professionals.

 

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