It’s that time of year again! Some important compliance deadlines are coming up this fall and winter:
Summary Annual Report (SAR): A summary annual report (SAR) is a boiled-down summary of the Form 5500. A SAR is required for any plan subject to Form 5500 filing, except for self-insured plans without any segregation of assets in a trust or otherwise (unfunded).
Medicare Part D Notices: Employers offering prescription drug coverage must issue the Notice of Creditable Coverage to individuals by October 14. Model disclosure notices are available on the CMS website.
Note: Employers may provide the notice any time during the 12 months preceding October 14.
November 15 to
|Special Open Enrollment Period for Small Groups: The ACA requires carriers to offer a one-month special open enrollment period (SEP) each year from November 15 to December 15 for a January 2023 effective date. The SEP is for groups that don’t have to meet contribution or participation requirements as long as they meet all other standard rules.|
|December 27 - NEW for 2022!||
Effective 2022, Plans must submit certain information about prescription drug and health care spending to the Departments annually. First deadline for Drug Cost Reporting is December 27, 2022.
For more information, review Amwins Connect Guidance-CAA-Drug Cost Reporting Requirements
MLR Rebate Distribution: ERISA plan sponsors who received a Medical Loss Ratio (MLR) rebate on September 30th must pay the appropriate rebate amount to participants. If a plan sponsor paid the entire cost of the insurance, the employer could retain the entire rebate.
The most common situation is when the plan sponsor and participants contribute toward the cost of coverage. In this case, the plan sponsor must determine the portions of the total plan cost contributed by both parties so the MLR rebate can be allocated among participants, plan costs, and the employer.
Plan sponsors must first determine total participant contributions for the year used to calculate the MLR rebate. Current rebates are based on premiums paid to the carrier for the calendar year 2021.
For Carrier specific rebate information review Amwins Connect Medical-Loss-Ratio MLR Results 2021 Plan Year
|Non-Calendar Year Plans - Medicare Part D Creditable Coverage Reporting to CMS||
Employers sponsoring prescription drug plans must report to CMS within 60 days after the beginning of the plan year regardless of whether the coverage is creditable.
For plan years beginning September 1, 2022 – due October 31, 2022
For more information review CMS Medicare Prescription Drug Creditable Coverage Disclosure Form and Instructions
Contact your Amwins Connect Sales Team for compliance support.