Upcoming Group Health Plan Annual Reporting Deadlines

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Bass, Berry & Sims PLC

With all the recent and pending changes shaking up the Employee Benefits world, at least a few things are remaining constant.  Here are a few upcoming annual reporting deadlines for group health plans:

The annual M-1 filing deadline for Multiple Employer Welfare Arrangements (MEWAs) is March 1, 2017.  However, if the MEWA filed an M-1 between October 1 and December 31, 2016, upon origination or certain other events (such as entering a new state), the annual filing is not required for this March 1.

The Online Disclosure to CMS to report the creditable coverage status of a prescription drug plan should be completed within 60 days from the beginning of a plan year (or within 30 days after termination of a prescription drug plan, or 30 days after any change in creditable coverage status).  For a calendar-year plan, this generally means that it is due by March 1, 2017.

DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations. Attorney Advertising.

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