Key Q4 Compliance Deadlines for Employer-Sponsored Group Health Plans*
Deadline
Requirement
Action Item
Ensure required notice is provided annually to each participant and beneficiary (may be included with open enrollment materials or in the SPD, if distributed annually)
Annually
WHCRA Notice
Notice of Premium Assistance Under Medicaid and the Children’s Health Insurance Program (Employer Chip Notice)
Ensure required notice is provided annually to all employees (may be provided with the SPD, enrollment packets, or open season materials, if such materials are provided to all employees and in accordance with all DOL disclosure rules)
Annually
(ERISA § 701(f)(3)(B)(i)))
Note: This requirement applies to employers that maintain a group health plan in a state that provides premium assistance under Medicaid or CHIP.
JENNIFER S. KIESEWETTER – Partner
KATIE REYNOLDS – Associate
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