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

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.
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.
Compliance Tracker – April

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
2024 HR Calendar Monthly Reminders

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.
December HR Compliance Deadlines 2023

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.
November HR Compliance Deadlines 2023

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:
October HR Compliance Deadlines 2023

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.
September Compliance Deadlines 2023

KEY DEADLINES
Sept. 30, 2023—Provide SAR to plan participants (calendar year plans only) – if Form 5500 deadline was not extended Provide a summary annual report (SAR) to plan participants by Sept. 30, 2023, if the employee benefit plan’s Form 5500 deadline was not extended. The SAR must be provided within nine months of the close of the plan year unless the plan’s Form 5500 deadline was extended. Plans exempt from the annual 5500 filing requirement are not required to provide an SAR. Unfunded welfare plans are also generally exempt from the SAR requirement.