February and March 2016 Filing and Notice Deadlines for Qualified Retirement and Health and Welfare Plans

King & Spalding
Contact

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. To avoid such penalties, employers should remain informed with respect to the filing and notice deadlines associated with their plans.

The filing and notice deadline table below provides key filing and notice deadlines common to calendar year plans for the next two months. If the due date falls on a Saturday, Sunday, or legal holiday, the due date is generally delayed until the next business day. Please note that the deadlines will generally be different if your plan year is not the calendar year. Please also note that the table is not a complete list of all applicable filing and notice deadlines (including any available exceptions and/or extensions), just the most common ones.

Deadline

Item

Action

Affected Plans

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

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.

Defined Contribution Plans that allow participants to direct investments

Benefit Statements for Participant-Directed Plans

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

February 29 (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 March 31.

 

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

Plan Contribution Deadline

Deadline for corporate employer contributions to be made to plan trusts in order for such amounts to be deductible on corporate tax returns (assuming the employer is operating on a calendar-year fiscal year). Note that this deadline may be extended if an extension is obtained for the corporate tax return.

Qualified Retirement Plans

March 15
(2½ 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

March 31

IRS Form 1095-B Individual Statements

Deadline for providers of minimum essential coverage to distribute forms used to report to responsible individuals the months during the year that the individuals satisfied the individual mandate by enrolling in minimum essential coverage. This deadline was extended from its original deadline of January 31.

Note that self-insured plan sponsors that employed an average of at least 50 full-time employees  in 2015 (also known as “Applicable Large Employers” or “ALEs”) can report this information on Form 1095-C.  Fully insured plan sponsors that are not ALEs are not required to distribute Form 1095-B, which are distributed by the group health plan insurers.

Self-Insured Group Health Plans and Group Health Plan Insurers

IRS Form 1095-C Individual Statements

Deadline for ALEs to report to provide a written statement to employees indicating whether the ALEs offered an opportunity to enroll in (and whether the employee did enroll in) minimum essential coverage under the ALE’s sponsored plan. This deadline was extended from its original deadline of January 31.

Applicable Large Employers


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

Written by:

King & Spalding
Contact
more
less

King & Spalding on:

Reporters on Deadline

"My best business intelligence, in one easy email…"

Your first step to building a free, personalized, morning email brief covering pertinent authors and topics on JD Supra:
*By using the service, you signify your acceptance of JD Supra's Privacy Policy.
Custom Email Digest
- hide
- hide