BFG Benefits Brief and HR Newsletter - January 2020
Upcoming Group Health Plan Compliance Dates
Employers must comply with numerous reporting and disclosure requirements throughout the year in connection with their group health plans.
Listed below are upcoming important compliance deadlines for employer-sponsored group health plans, organized chronologically. For these requirements, the information provided herein shows the deadlines that apply to calendar year plans. For non-calendar year plans, these deadlines will need to be adjusted to reflect each plan’s specific plan year.
Employers that filed 250 or more IRS Forms W-2 for the prior calendar year must file Forms W-2 with the Social Security Administration and furnish Forms W-2 to employees by Jan. 31 of each year, unless an extension applies.
ALEs that sponsor fully or self-insured health plans are required to report information about the coverage to the IRS each year, using IRS Forms 1094-C and 1095-C. Employers that are not ALEs use IRS Forms 1094-B and 1095-B to meet these reporting obligations. The deadline for filing paper versions of the forms is Feb. 28, 2020. The deadline for electronic filing is March 31, 2020.
Group health plan sponsors that provide prescription drug coverage to Medicare Part D-eligible individuals must disclose to the Centers for Medicare & Medicaid Services (CMS) whether prescription drug coverage is creditable or non-creditable within 60 days after the beginning of the plan year. For calendar year plans, the deadline is March 1, 2020.
ALEs that sponsor fully or self-insured health plans to report information about the coverage to covered employees each year, using IRS Form 1095-C. Employers that are not ALEs use IRS Form 1095-B to provide this information. The IRS recently extended the deadline for furnishing 2019 employee statements, from Jan. 31, 2020, to March 2, 2020.
The electronic filing deadline for Code Sections 6055 and 6056 reporting is March 31, 2020. ALEs that sponsor fully or self-insured health plans are required to report information about the coverage to the IRS each year, using IRS Forms 1094-C and 1095-C. Employers that are not ALEs use IRS Forms 1094-B and 1095-B to meet these reporting obligations.
5 Performance Review Best Practices
Performance reviews are an annual ritual for many employers, but their usefulness has been debated for years.
To make sure you—and your employees—get the most out of performance reviews, follow these five tips.
- Perform formal evaluations at the same time for everyone each year. While this increases the workload of managers and supervisors during review time, it forces direct comparisons of employees and establishes a nonbiased system.
- Have regular meetings with supervisory staff. Supervisors will learn from each other’s experiences. Provide adequate training and insist on candid observations.
- Clearly communicate to employees what their duties are and what satisfactory performance is. Accomplish this through periodic reviews of job descriptions, training, and both formal and informal reviews.
- Tell employees the criteria upon which their performance will be reviewed. Develop standards and establish reasonable goals for employees. Make sure that employees understand the consequences of their failure to improve.
- Don’t wait until the annual evaluation to provide feedback; offer it throughout the year. Give both positive and negative feedback regularly or it becomes less useful.
New Summary of Benefits and Coverage Template Will Be Required for 2021
Recently, the Departments of Labor (DOL) and Health and Human Services (HHS) issued an updated template and related materials for the summary of benefits and coverage (SBC). These materials are required to be used for plan years beginning on or after Jan. 1, 2021. This means that the updated template must be used for the 2021 plan year’s open enrollment period.
The SBC is a concise document providing simple and consistent information about health plan benefits and coverage.
Employers should prepare to use the new SBC template and related materials for the 2021 plan year. Prior to the beginning of the 2021 plan year:
- Self-funded plan sponsors should ensure that they use the new template.
- Employers with insured plans should make sure the carrier is providing the correct version of the template.
Should you have any questions about these issues or others related to Corporate Benefits, please do not hesitate to contact a member of Brooks Financial Group's Corporate Benefits Consulting team using the contact information below.
Newsletter provided by:
Brooks Financial Group, Inc.
1020 Cromwell Bridge Road, Towson, MD 21286
The content herein is provided for general information purposes only, and does not constitute legal, tax, or other advice or opinions on any matters. This information has been taken from sources which we believe to be reliable, but there is no guarantee as to its accuracy.
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