As year-end approaches, group health plan sponsors must meet federal reporting and disclosure deadlines to stay compliant and avoid penalties. The table below highlights key year-end deadlines for calendar-year group health plans.
|
Requirement |
Description |
Deadline |
|
Summary Annual Reports (SARs) |
Plan administrators who file Form 5500 must provide participants with an SAR summarizing the report within nine months of the plan year’s end, unless an extension was granted. |
September 30, 2025 |
|
Medicare Part D Notices |
Employers with group health plans must notify Medicare Part D eligible individuals each year if their prescription coverage is creditable. |
October 14, 2025 |
|
Form 5500s (Extended Deadline) |
ERISA-covered employers must file Form 5500 electronically each year unless exempt. For calendar-year plans, the 2024 report was due July 31, 2025. Filing IRS Form 5558 provides a 2.5-month automatic extension. |
October 15, 2025 |
|
SARs (Extended Deadline) |
If a Form 5500 extension is granted, the SAR must be provided within two months after the extension ends. |
December 15, 2025 |
|
Gag Clause Attestation |
Health plans must attest annually to compliance with the CAA’s gag clause prohibition. Fully insured employers are covered if their issuer reports. Self-insured plans can delegate but remain legally responsible. |
December 31, 2025 |
|
HRA-specific Deadlines |
||
|
Individual Coverage HRA (ICHRA) Notice |
Employers offering ICHRAs must notify eligible participants about the plan and its interaction with the ACA premium tax credit at least 90 days before the plan year starts. |
October 3, 2025 |
|
Qualified Small Employer HRA (QSEHRA) Notice |
Employers offering a QSEHRA must provide notice to each eligible employee at least 90 days before the plan year begins. |
October 3, 2025 |
In addition to the above deadlines, the end of the plan year is a good time to make sure that annual notices have been distributed. Download the bulletin for more details.