2021 Health Plan Compliance Deadlines
Posted April 28, 2021
Employers must comply with numerous reporting and disclosure requirements throughout the year in connection with their group health plans. This Compliance Overview explains key 2021 compliance deadlines for employer-sponsored group health plans. It also outlines group health plan notices that employers must provide each year.
Some of the compliance deadlines summarized below are tied to a group health plan’s plan year. For these requirements, the chart below shows the deadline that applies to calendar year plans. For non-calendar year plans, these deadlines will need to be adjusted to reflect each plan’s specific plan year.
Determining the Plan Year
The “plan year” is the calendar, policy or fiscal year on which the records of the plan are kept. Many employers operate their group health plans on a calendar year basis, from Jan. 1 through Dec. 31 of each year. Other employers operate their plans on a non-calendar year basis, which may be consistent with the company’s taxable year or with an insured plan’s policy year.
2021 Compliance Deadlines
COVID-19-Related Deadline Extensions
On April 28, 2020, the DOL issued Disaster Relief Notice 2020-01 to extend the time to furnish benefit statements and other notices and disclosures required under ERISA, so that plan sponsors have additional time to meet their obligations during the COVID-19 outbreak. Under this guidance, an employee benefit plan will not be in violation of ERISA for a failure to timely furnish a notice, disclosure or document that must be furnished between March 1, 2020, and 60 days after the announced end of the COVID-19 National Emergency, if they act in good faith. This means the plan must furnish the documents as soon as administratively practicable under the circumstances.
Key notices and disclosures required under ERISA include the summary plan description (SPD), summary of material modifications (SMM), summary of benefits and coverage (SBC), Notice of Patient Protections, Notice of Grandfathered Status, wellness program disclosure under HIPAA, CHIP Notice and Women’s Health and Cancer Rights Act Notice.