June and July 2015 Filing and Notice Deadlines for Qualified Retirement and Health and Welfare Plans

King & Spalding
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[author: Ryan Gorman]

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 for the next two months. If the due date falls on a Saturday, Sunday, or legal holiday, the due date is 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. 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

June 30

(last day of 6th month following the plan year)

Excess Contributions

Deadline for plan administrator to distribute eligible automatic contribution arrangements (EACA) excess contributions and earnings from the prior year to avoid 10% excise tax.

401(k) Plans with EACA

July 29 (no later than 210 days after the end of the plan year in which the change was effective)

Summary of Material Modifications

Deadline for plan administrator to distribute summary of material modifications reflecting any changes to the summary plan description SPD) arising from any plan amendments adopted during prior year (unless a revised SPD is distributed that contains the modification).

Retirement Plans

Health & Welfare Plans

July 31

(the last day of the 7th month following the plan year)

DOL Form 5500

Deadline for plan administrator to file Form 5500 (Annual Return/Report of Employee Benefit Plan) for prior year. This deadline is extended 2 ½ months if the plan administrator files Form 5558.

Retirement Plans

Health and Welfare Plans

IRS Form 8955-SSA

Deadline for plan administrator to file Form 8955-SSA (Annual Registration Statement Identifying Separated Participants with Deferred Vested Benefits). This deadline is extended by 2 ½ months if the plan administrator files a Form 5558.

Retirement Plans

July 31, 2015

Patient Centered Outcomes Research Institute (PCORI) Fee

Deadline for self-insured health plans to pay a fee for 2014 plan year using IRS Form 720. Note that the fee is not tax deductible. Insurers are responsible for paying the fee on behalf of insured plans.

Self-Insured Group Health Plans (including retiree plans)

 

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