Compliance Updates and Reminders
The end of the year tends to be very busy for most of us, so we’d like to remind you of some upcoming compliance dates as we move closer to 2017:
- W2 statements. W2s must be mailed to individuals by January 31. Please refer to our Self-funded Health Plan Compliance Calendar for more information on these this requirements.
- Deadline tracking. Please be sure to use our Self-funded Health Plan Compliance Calendar to keep track of these dates and more throughout the year. Our calendar includes requirements that do not have a static date such as the annual notices (if applicable) for WHCRA, CHIPRA and the new Wellness Notice, which must be sent to wellness plan program participants before information related to the program can be collected from them. You can read more about the Wellness Notice in our previous article.
- IRS Releases Salary Reduction Limits for 2017. On October 25th, the IRS released the annual inflation rates for tax related limits to salary reductions for 2017. This cost of living adjustment applies to employers who offer Flexible Spending Accounts, transportation and adoption benefits. Increasing the dollar limits to match the increased maximums is optional. Please check out Annual Inflation Rates for FSAs and view the below for more information on adjustments for 2017:
Type of Filing Former penalty amount New penalty amount Qualified Transportation Fringe Benefit/Transit Passes and Vanpooling $255/month $255/month (no change) Adoption Credit $13,460 $13,570 (increased by $110.00) Health FSA $2,550 $2,600 (increased by $50.00) Penalty Former penalty amount New penalty amount Minimum Essential Coverage Penalty $695 $695 (no change)
To whom does this apply? This cost of living adjustment applies to employers who offer Flexible Spending Accounts, Transportation and Adoption benefits.
What steps must employers take to comply? No action is required. Increasing the dollar limits to match the increased maximums is optional.
When do these rates go into effect? These rates are applicable to the 2017 tax year.
- PCORI Fee Announced for 2017. On November 4, 2016, the Internal Revenue Service (IRS) announced the PCORI fee for 2017. As a reminder, this fee applies to all plans* with plan years ending on or after October 1, 2012. This fee is a temporary fee and is scheduled to sunset as of September 30, 2019. Please view the Self-Funded Health Plan Compliance Calendar to help you keep track of the deadline associated with this fee and to read more about it.
- Form 5500 Changes. The Department of Labor has released the Form 5500 documents for the 2016 filing year. This form is used to collect financial, actuarial, and operational details on employee benefit plans subject to ERISA. As a reminder, those who need to comply must file their 5500 annually prior to the last day of the seventh calendar month following the end of their plan year. No changes have been made to the main document for 2016 but there have been changes to schedules A, H, I and R. Additionally, there is a significant increase to the penalties for failure to comply with these requirements. The penalty will increase from $1,100 to $2,063 per day. We can provide reports to help you in obtaining information you’ll need for completing this filing.
- Extension granted for furnishing individual 1095-B and 1095-C documents. On November 18, the Department of the Treasury announced they recognize entities who provide minimum essential coverage need additional time beyond the January 31, 2017, to prepare their 2016 Forms 1095-B and 1095-C to be furnished to individuals. Accordingly, they have extended by 30 days the due date for furnishing the 2016 Form 1095-B and the 2016 Form 1095-C: from January 31, 2017, to March 2, 2017. Employers and other coverage providers are encouraged to furnish 2016 statements as soon as they are able, but now have until March 2, 2017, to provide these forms. IMPORTANT NOTE: There is no similar extension for employers to file with the IRS their 2016 Forms 1094-B, 1095-B, 1094-C and 1095-C. Those due dates remain at February 28, 2017, if not filing electronically, or March 31, 2017, if filing electronically.
Please contact your Client Solutions team if you have any questions.
Compliance Corner is being provided as an informational tool. It is recommended that plans consult with their own experts or counsel to review all applicable federal and state legal requirements that may apply to their group health plan. By providing this publication and any attachments, Meritain Health is not exercising discretionary authority over the plan and is not assuming a plan fiduciary role, nor is Meritain Health providing legal advice.