In response to the COVID-19 pandemic, the IRS has issued Notice 2020-23, which automatically extends the deadlines for certain filing obligations that would otherwise be due on or after April 1, 2020, and before July 15, 2020. Since the relief is automatic, no action is needed by plan sponsors to take advantage of the extended deadlines.

Form 5500 filings for plan years that ended in September, October or November 2019, as well as Form 5500 deadlines falling between April 1 and July 15, 2020, as a result of a previously filed extension request are now due July 15, 2020.

Applications & Exceptions

Note that the extension does not apply to the July 31, 2020, due date for 2019 Form 5500 filings for calendar-year employee benefit plans. However, those plans still may seek a regular extension using Form 5558. The extended deadlines also apply to correcting excess retirement plan contributions based on nondiscrimination testing and excess deferrals (normally due by April 15, 2020), plan loan repayments, the 60-day window for rollovers, and the deadline for filing Form 8955-SSA to report separated plan participants with undistributed vested benefits.

Health & Medical Savings Accounts

The relief also extends from May 31 to July 15, 2020, (1) the 60-day time frame for completing HSA (or Archer MSA) rollovers and (2) the deadline to report HSA (or Archer MSA) contribution information by filing Form 5498-SA and providing the information to account holders.