Reminder here are some important dates to keep in mind for the first quarter of 2019 as it relates to employer compliance.
January 31, 2019 - Employers who issue 250 or more W-2 statements are required to report the aggregate cost of applicable employer-sponsored coverage on an employee's W-2 statement. These employers must have their employees’ 2018 W-2s postmarked by this date. Exception apply (tribal plans, stand-alone dental and vision). Contact your tax advisor to determine what is to be included on your W-2s.
February 28, 2019 - Applicable Large Employers (ALEs) with 50 or more full-time employees and full-time employee equivalents (FTEs) must submit their 6056 filing to the IRS by this date if filing a paper return. Paper returns are only allowed if filing less than 250 of any form.
March 1, 2019 - Administrators of plans that provide benefits through a Multiple Employer Welfare Arrangement (MEWA) that are subject to ERISA must submit their M-1 filing by this date. The M-1 form to complete this filing can be found online or by clicking here as well a Tips from the Department of Labor.
March 1, 2019 - Group health plans that provide prescription drug benefits to Medicare Part D–eligible individuals within their group Medical plan (with eligibility based on attaining age 65 or being disabled prior to age 65) must submit their Medicare Part D Notice of Creditable Coverage Disclosure to CMS 60 days after the first day of the plan year. March 1st is the deadline for group's with Calendar Year plans. The CMS online Disclosure Form can be found here.
March 4, 2019 - All employer-sponsored health plans, regardless of group size, must provide 6055 individual notices by this date. The original deadline of January 31st was extended as noted in our previous post "What Every HR Needs to Know - ACA Reporting 2019". The notice must be provided to all members covered for at least one day during the calendar year, and includes information about their coverage. This requirement may be satisfied by simply copying the IRS form. IRS Publication 5223 covers the requirements for acceptable substitutes of the IRS Forms. The 6055 filing to the IRS is due by February 28 if filing a paper return or by March 31 if filing electronically.
March 31, 2019 - Applicable Large Employers (ALEs) with 50 or more full-time employees and full-time employee equivalents (FTEs) must submit their 6056 filing to the IRS by this date if filing a paper return. Electronic returns are only allowed if filing more than 250 of any form.