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Medicare Part D notice Deadline Coming Soon
Every year, employers with group health plans must send a Medicare Part D Creditable (or Non-Creditable) Coverage Notice to inform employees whether their plan’s prescription drug coverage meets or falls short of Medicare Part D standards. With significant changes to Medicare Part D coming in 2025, employers should monitor updates to the simplified creditability method and adjust their notices as needed.

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HIPAA, Medicare and SBC Penalties Increase Again

The U.S. Department of Health and Human Services recently updated penalty amounts for HIPAA, the Affordable Care Act, and Medicare Secondary Payor violations, with HIPAA penalties being particularly relevant for sponsors of self-funded health plans.

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Winds of Change: Mid-Year Contribution Changes

Employers typically set contributions for benefit plans annually but may adjust them mid-year, often increasing contributions due to financial factors, though they may decrease them to comply with the ACA or improve competitiveness for talent.

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Don't Forget These Deadlines

September 30

For calendar year plans, distribute Summary Annual Reports (SARs) to participants, COBRA beneficiaries and alternate recipients under QMCSOs within 9 months after close of the plan year or two months after the plan's extended 5500 deadline. SAR requirement does not apply to plans that pay benefits exclusively from the employer's general assets (i.e. no trust, no insurance contract, participant contributions are made through a Section 125 plan, etc.).

October 15

Distribute Medicare Part D Notices of Creditable and/or Non-Creditable Coverage. These are sent to employees, retirees and dependents enrolled in or eligible for Medicare and also enrolled (or seeking enrollment) in the employer's plan.

October 15

File Form 5500 (for a calendar year plan), if you filed for an extension.  If Form 5558 was submitted to the IRS seeking an extension of the deadline to submit Form 5500, filing of Form 5500 is now required.

*For deadlines based on the timing of your plan year, contact your HUB account manager or refer to the HUB Compliance Calendar.

Workforce Absence Management Directory

In addition to receiving absence management updates here, you can find the latest state workforce absence and leave management regulations and insights in the HUB Workforce Absence Management Directory.

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Contributing authors to In Compliance: