February and March 2014 Filing and Notice Deadlines for Qualified Retirement and Health and Welfare Plans

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Author, Ryan Gorman, Atlanta, +1 404 572 4609, rgorman@kslaw.com

Employers and plan sponsors must comply with numerous filing and notice deadlines for their retirement and health and welfare plans. Failure to comply with these deadlines can result in costly penalties and excise taxes. To avoid such penalties and excise taxes, employers must remain informed with respect to the filing and notice deadlines associated with their plans. The filing and notice deadline table below provides key 2014 filing and notice deadlines common to calendar year plans for the next two months. Please note that the deadlines will be different if your plan year is not the calendar year. Please also note that the table does not include all applicable filing and notice deadlines, just the most common ones. King & Spalding is happy to assist you with any questions you may have regarding compliance with the filing and notice requirements for your employee benefit plans.

Deadline

Item

Action

Affected Plans

February 14 (within 45 days after the close of the fourth quarter of previous plan year)

Quarterly Benefit Statements for Participant-Directed Plans

Deadline for plan administrator to send quarterly benefit statement for the fourth quarter of previous plan year to participants in participant-directed defined contribution plans.

Defined Contribution Plans that allow participants to direct investments

Quarterly Fee Disclosure

Deadline for plan administrator to disclose fees and administrative expenses deducted from participant accounts during the fourth quarter of the previous plan year. Note that the quarterly fee disclosure may be included in the quarterly benefit statement or as a stand-alone document.

February 25

2013 Comparative Chart of Investment Alternatives

Deadline for plan administrator to furnish the 2013 comparative chart of investment alternatives (originally required to be furnished by August 30, 2013), if plan administrator took advantage of a one-time delay to align the timing with that of other plan enrollment materials.

Defined Contribution Plans with participant-directed investments

February 28 (if filing paper forms)

IRS Form 1099-R

Deadline for employer to file IRS Form 1099-R. If the form is filed electronically, the deadline can be extended until April 1.

Qualified Retirement Plans*

March 1
(60 days after the beginning of the plan year)

Medicare Part D Creditable Coverage Disclosure

Deadline for employers that provide prescription drug coverage to Medicare Part D eligible individuals to disclose to the Centers for Medicaid and Medicare Services (CMS) whether the coverage is “creditable prescription drug coverage” by completing the Online Disclosure to CMS Form at https://www.cms.gov/Medicare/Prescription-Drug-Coverage/CreditableCoverage/CCDisclosureForm.html

Health and Welfare Plans that provide prescription drug coverage to Medicare Part D eligible individuals

March 15
(2 ½ months after the plan year)

Excess Contributions

Deadline for plan administrator to distribute any excess contributions and earnings from the prior year to avoid 10% excise tax on employer (other than eligible automatic contribution arrangements (EACAs)).

401(k) Plans Other Than EACAs

March 31
(last day of 3rd month following the end of the prior plan year)

Certification of Adjusted Funding Target Attainment Percentage (AFTAP)

Deadline for actuary to certify AFTAP to avoid presumption that AFTAP is 10 points less than prior year AFTAP.

Defined Benefit Plans


* Qualified Retirement Plans include all defined benefit and defined contribution plans that are intended to satisfy Code §401(a).

Topics:  Compliance, Employee Benefits, Filing Deadlines, Health and Welfare Plans, Healthcare, Retirement Plan

Published In: Finance & Banking Updates, Health Updates, Labor & Employment Updates, Tax Updates

DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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