Category: Compliance Bulletin

Compliance Bulletin – Medicare Part D Changes May Impact Creditable Coverage Status of Employer Plans

The Inflation Reduction Act of 2022 (IRA) includes several cost-reduction provisions affecting Medicare Part D plans, which may impact the creditable coverage status of employer-sponsored prescription drug coverage beginning in 2025.

Employers that provide prescription drug coverage to individuals who are eligible for Medicare Part D must inform these individuals and the Centers for Medicare and Medicaid Services (CMS) whether their prescription drug coverage is creditable, meaning that the employer’s prescription drug coverage is at least as good as Medicare Part D coverage

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Compliance Bulletin – Mental Health Parity Compliance Remains a Key Focus in 2024

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The federal government is continuing its efforts to improve access to mental health and substance use disorder (MH/SUD) care in 2024, with a top enforcement priority being compliance with the Mental Health Parity and Addiction Equity Act (MHPAEA) for employer-sponsored health plans.


MHPAEA is a federal law that prevents group health plans and health insurance issuers that provide MH/SUD benefits from imposing more restrictions on those benefits than what generally applies to comparable medical or surgical benefits.

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Compliance Bulletin – Form 5500 Deadline is July 31st

Each year, employers that are subject to the Employee Retirement Income
Security Act of 1974 (ERISA) must electronically file an annual report
(Form 5500) for each employee benefit plan they maintain unless a filing
exemption applies.

Employers with employee benefit plans that operate on a calendar year
basis must file their annual reports for 2023 with the U.S. Department of
Labor (DOL) by July 31, 2024. An employer may extend this deadline by
2.5 months (until Oct. 15, 2024) by filing Form 5558 with the IRS by July
31, 2024.

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Compliance Tracker – April

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A | Filing Deadline for Affordable Care Act (ACA) Returns (Electronic Reporting) – April 1, 2024

Applicable large employers (ALEs) and non-ALEs with
self-insured plans must file their ACA returns with the
IRS by April 1, 2024, if filing electronically. Beginning
in 2024, most employers are required to file their ACA
returns electronically.

B | EEO-1 Data Collection Begins – April 30, 2024

Employers with 100 or more employees and certain
federal contractors must file EEO-1 reports with the
Equal Employment Opportunity Commission (EEOC)
each year. The EEOC’s portal for submitting EEO-1 reports
from 2023 is scheduled to open on April 30, 2024.

C | Posting Period Ends for OSHA Form 300A – April 30, 2024

Employers may remove their OSHA Form 300A posting
at any time on or after April 30, 2024. This form, which
summarizes workplace data from 2023, must be posted
from Feb. 1, 2024, until April 30, 2024

View and download the HR Calendar Monthly Reminders

HR Compliance Bulletin: Preparing for the DOL’s New Overtime Rule

In early March 2024, the U.S. Department of Labor’s (DOL) proposed
overtime rule, announced in August 2023, entered its last stage of review.
Publication of the final rule is expected soon. The rule would amend the
requirements that employees in certain white-collar occupations must
satisfy to qualify for an overtime exemption under the Fair Labor
Standards Act (FLSA).

The FLSA white-collar exemptions apply to individuals in executive,
administrative, and some outside sales personnel and computer-related
occupations. Some highly compensated employees (HCEs) may also
qualify for a FLSA white-collar exemption.

For more info, download the latest compliance overview below.

Click here to view and download the latest HR Compliance Overview

HR Compliance Overview: What Employers Should Know About EEO Retaliation

The U.S. Equal Employment Opportunity Commission (EEOC) is a federal agency responsible for enforcing federal equal employment opportunity (EEO) laws. Each EEO law listed below covers certain private-sector employers and prohibits retaliation and related conduct. Retaliation occurs when an employer penalizes an employee or applicant for asserting his or her right to be free from discrimination under the EEO laws, including:

  • Title VII of the Civil Rights Act of 1964 (Title VII)
  • The Equal Pay Act of 1963 (EPA)
  • The Age Discrimination in Employment Act of 1967 (ADEA)
  • Titles I and V of the Americans with Disabilities Act of 1990 (ADA)
  • Title II of the Genetic Information Nondiscrimination Act of 2008 (GINA)
  • The Pregnant Workers Fairness Act of 2022 (PWFA)

For more info, download the latest compliance overview below.

Click here to view and download the latest HR Compliance Overview

2024 HR Calendar Monthly Reminders

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Between navigating the changing economic environment, addressing new attraction and retention
trends and balancing day-to-day operations, 2024 will likely be a busy and challenging year
for HR professionals. So, now is the time for HR teams to prepare their organizations and employees
for 2024. Creating a calendar of reminders will allow HR professionals to be more organized
and productive throughout the year.

View and download the HR Calendar Monthly Reminders

December HR Compliance Deadlines 2023

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KEY DEADLINES

Dec. 15, 2023—Provide SAR to plan participants (calendar- year plans only) – if Form 5500 deadline was extended Provide an SAR to covered employees by Dec. 15, 2023, if the plan’s form 5500 deadline was extended. In general, the SAR must be provided within nine months of the close of the plan year. However, if the plan’s Form 5500 deadline was extended, the SAR must be provided within two months after the close of the extension period. For calendar-year plans, this extended deadline is Dec. 15, 2023. Plans that are exempt from the annual 5500 filing requirement are not required to provide a SAR. Unfunded welfare plans are also generally exempt from the SAR requirement.



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November HR Compliance Deadlines 2023

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KEY DEADLINES

COMPLIANCE REMINDERS
As the end of the year approaches, consider taking the following steps to encourage employees to utilize any unused benefits for 2023:



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October HR Compliance Deadlines 2023

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KEY DEADLINES

Oct. 3, 2023—Provide ICHRA notice for 2024 plan year
(calendar year plans only)
Employers who offer individual coverage health reimburse-ment arrangements (ICHRAs) must provide a notice to eligible employees regarding the ICHRA’s coverage. This notice must be provided at least 90 days before the beginning of each plan year. For ICHRAs that operate on a calendar year basis, this notice must be provided by Oct. 3, 2023, for the upcom-ing 2024 plan year. A model notice is available for employers to use.



View and download the HR October Compliance Deadlines