Keeping up with health plan reporting deadlines can feel manageable until several of them start stacking up at once. In this episode of Comply on the Fly, Karen walks through the key annual filings and disclosures plan sponsors need to keep on their radar, including ACA reporting, Medicare Part D disclosure to CMS, RxDC, Form 5500, PCORI fees, and gag clause attestation.
She breaks down what each item is, when it is typically due, and where employers may need to coordinate with carriers, TPAs, PBMs, or other partners to make sure nothing slips through the cracks. If you want a practical refresher on the reporting requirements that come up year after year, this episode is a quick, useful listen.
Tune in, then use the chart below as a handy reference for the forms, deadlines, and reporting obligations covered in the episode.
Annual government reporting deadlines
ACA Reporting
| Form/Filing | Who it applies to | Deadline |
|---|---|---|
| Forms 1094-C and 1095-C, or 1094-B and 1095-B | Applicable Large Employers and non-ALEs with self-funded plans | Employee statements: March 2 IRS electronic filing: March 31 |
Medicare Part D
Creditable or non-creditable coverage disclosure to CMS
| Form/Filing | Who it applies to | Deadline |
|---|---|---|
| Online disclosure to CMS | Plan sponsors offering prescription drug coverage to Medicare-eligible individuals | Within 60 days after the start of the plan year |
RxDC Reporting
| Form/Filing | Who it applies to | Deadline |
|---|---|---|
| Prescription Drug Data Collection submission to CMS | Group health plans and issuers, whether fully insured or self-funded | June 1 |
Form 5500 filing
| Form/Filing | Who it applies to | Deadline |
|---|---|---|
| Form 5500 | ERISA-covered employee benefit plans, unless an exemption applies | July 31 |
Gag clause attestation
| Form/Filing | Who it applies to | Deadline |
|---|---|---|
| GCPCA submission through CMS | Group health plans and issuers | December 31 |
Please Note: This podcast and the contents herein do not constitute legal advice. Seek the advice of counsel for any benefit compliance related implementation guidance or strategy.
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