Compliance Calendar
Summary Annual Report (SAR) Deadline (For Calendar Year Plans)
ERISA plan administrators are required to provide covered participants and certain beneficiaries with an annual statement summarizing the latest annual report Form 5500 for the plan. The SAR is due within nine months of the close of the plan year; two months after the extended due date for filing the Form 5500. DOL regulations require that certain categories of information be covered in the SAR. A sample SAR is included in the DOL regulations (29 CFR 2520.104b-10), and the DOL also provides a SAR template. (Due September 30, 2024 for calendar year plans; December 15, 2024 if an extension is filed.)
VETS-4212 Filing Deadline (federal contractors)
The deadline for federal contractors to file the VETS-4212 Report is September 30. The VETS-4212 Report must be completed by all nonexempt federal contractors and subcontractors with a contract or subcontract of $150,000 or more with any U.S. department or agency for the procurement of personal property or nonpersonal services. Services include, but are not limited to: utility, construction, transportation, research, insurance, and fund depository, irrespective of whether the government is the purchaser or seller. Entering into a covered federal contract or subcontract during a given calendar year establishes the requirement to file a VETS-4212 Report during the following calendar year.
QSEHRA Notice Deadline (Calendar Year Plans Only)
Small employers that offer a Qualified Small Employer Health Reimbursement Arrangement (QSEHRA) are required to provide written notice to eligible participants at least 90 days before the beginning of each plan year. Sample language is provided under Q&A #38 of IRS Notice 2017-67. For purposes of calendar year plans, this date is October 1, 2024.
Medicare Part D Creditable/Noncreditable Coverage Notice
The Centers for Medicare and Medicaid Services (CMS) requires plan sponsors that provide prescription drug coverage to furnish Part-D-eligible individuals with a notice disclosing the creditable or non-creditable status of their coverage before October 15, 2024.
Form 941 Filing Deadline (third quarter)
Deadline for filing Form 941. Employer’s Quarterly Federal Tax Return, for the thrid quarter of the calendar year and depositing and undeposited income, Social Security, and Medicare taxes. You may pay these taxes with Form 941 if your total tax liability for the quarter is less than $2,500. If you timely deposited all taxes when due, you may file by November 10.
Gag Clause Prohibition Compliance Attestation
The Consolidated Appropriations Act, 2021, Title II, Division BB contains a reporting requirement for group health plans and health insurers to submit a Gag Clause Prohibition Compliance Attestation (GCPCA) annually through the Center for Medicare & Medicaid Services’ Health Insurance Oversight Systems to confirm compliance with the prohibition. Reporting is due by December 31, 2024.