Boon Buzz: Compliance Deadlines for Quarter 3 2019

Throughout the year, employers must comply with multiple reporting and disclosure requirements that are connected with their group health plans. As with everything else, when it comes to benefits, compliance is crucial. The third quarter of 2019 is no exception and marks another chapter of requirements and deadlines.

Check out our breakdown!

1. The PCORI Fee

The Patient-Centered Outcomes Research Institute Fee- New Window (or PCORI Fee) is a fee imposed on issuers of specified health insurance policies and plan sponsors of applicable self-insured plans by the Affordable Care Act, for funding purposes. The fee is only required to be reported once a year via Form 720, by July 31.

Employers with self-insured health plans must pay the PCORI Fee. Self-insured health plans that are subject to PCORI fees include self-funded medical plans, as well as HRA’s offered in conjunction with fully insured group medical plans. If an HRA is offered with a self-insured medical plan, it is not subject to a separate PCORI fee if that HRA and medical plan have the same plan sponsor and plan year.

2. Form 5500

Employers with ERISA-covered welfare benefit plans are required to file a Form 5500, annually. As this form must be filed by the last day of the seventh month following the end of the year, July 31 is the deadline for all calendar year plans. There is an exemption to filing Form 5500 for small health plans with fewer than 100 participants that are either fully insured, unfunded, or a combination of the two.

You can check out this blog post to learn even more!

3. Medical Loss Ratio Rebates

This compliance requirement applies to employers with fully insured health plans that receive MLR rebates. Issuers must spend a minimum percentage of their premium dollars (this is the MLR) on medical and health care. If an issuer does not meet the requirement, the applicable MLR must pay rebates to the group health plan if the plan sponsor is a government contractor.  If the plan sponsor is not a government contractor then the rebate may be paid to the plan sponsor

These rebates must be provided to plan sponsors or the group health plan by September 30, following the end of the MLR reporting year, for the benefit of the employees. If you receive a rebate, be mindful of some of the rules and legalities surrounding use of the rebate; if you are a government contractor then the rebate will be sent to The Boon Group and we will deposit it in trust to provide benefits for your employees.

It’s also a general rule of thumb that plan sponsors should use the rebate within 3 months of receiving it, to avoid ERISA’s trust requirements.

You can learn more about ERISA compliance and Boon’s related administrative services by clicking here.

4. Summary Annual Report

Employers that are required to file a Form 5500 must provide participants with a summary annual report. This report contains a summary of all the information found in Form 5500. Plan administrators must provide the SAR within nine months of the close of the plan year.

For calendar plans, the deadline is Sept. 30, 2019.

For plan administrators that requested an extension to file the Form 5500, the summary annual report must be furnished within two months after the close of that extension period.

Plans that are exempt from the annual 5500 filing requirement are not required to provide a summary annual report.

Compliance is Key

Compliance is a theme that comes up over and over again, when talking benefits in 2019. At Boon, compliance is a cornerstone of our fringe benefit solutions for government contractors.

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