February 2016 Employee Benefits Update

Compliance Deadlines and Reminders

Upcoming Health Plan Compliance Deadlines and Reminders

1. Medicare Part D Creditable Coverage Disclosure. Calendar-year plans providing prescription drug coverage must provide the annual creditable coverage disclosure to the Centers for Medicare and Medicaid Services ("CMS") by March 1, 2016 (or 60 days after the beginning of the plan year for noncalendar-year plans).
2. Form M-1.  Multiple employer welfare plans providing health coverage must electronically file the annual Form M-1 by March 1, 2016.  Employers may request a 60-day automatic extension in the filing.
3. Forms 1095‑B and 1095‑C.  Forms 1095-B and 1095-C must be distributed to participants and filed with the Internal Revenue Service ("IRS").  Plan sponsors of self-funded health plans and Applicable Large Employers ("ALE") must provide Forms 1095‑B and 1095‑C to employees by March 31, 2016.  Plan sponsors and ALEs should also file these forms with the IRS by May 31,