2020 Health Plan Compliance Deadlines

Every year employers that sponsor group health plans are subject to numerous reporting and disclosure requirements.

Not all compliance requirements will apply to every employer, but group health plan sponsors should familiarize themselves with health plan compliance deadlines. For non-calendar year plans, these deadlines will need to be adjusted to reflect each plan’s specific plan year.

How to Determine Your Plan Year

Your “plan year” is the calendar, policy, or fiscal year on which the records of the plan are kept. Many employers operate their group health plans from January 1st, through December 31st of each year.

Other employers operate their plans on a non-calendar year basis, which may be consistent with the company’s taxable year or with an insured plan’s policy year.

Below are some of the compliance deadlines that are tied to a group health plan’s plan year.

2020 Compliance Deadlines

Form W-2 (including health plan costs)

  • Deadline: January 31; applicable to employers that filed 250 or more IRS Forms W-2 for the prior calendar year.

Section 6056 and 6055 (individual statements)

  • Deadline: January 31; applicable to employers that are ALEs and sponsor fully insured health plans.
  • Deadline: January 31; applicable to employers that are not ALEs and sponsor self-insured health plans.

Section 6056 and 6055 (paper filing deadline)

  • Deadline: February 28; applicable to employers that are ALEs and sponsor fully insured health plans.
  • Deadline: February 28; applicable to employers that are not ALEs and sponsor self-insured health plans.

Medicare Part D disclosure to CMS (calendar year plans)

  • Deadline: March 1; applicable to group health plans that provide prescription drug coverage to individuals who are eligible for Medicare Part D.

Section 6056 and 6055 (electronic filing deadline)

  • Deadline: March 31; applicable to employers that are ALEs and sponsor fully insured health plans.
  • Deadline: March 31; applicable to employers that are not ALEs and sponsor self-insured health plans.

PCORI fee (for non-calendar year plans ending between Jan. 1, 2019 and Sept. 30, 2019)

  • Deadline: July 31; applicable to employers with self-insured health plans.

Form 5500 (regular deadline for calendar year plans)

  • Deadline: July 31; applicable to employers with ERISA-covered group health plans that do not qualify for the small plan exemption.

Medical loss ratio (MLR) rebates

  • Deadline: September 30; applicable to employers with fully insured health plans that receive MLR rebates.

Summary annual report (regular deadline for calendar year plans)

  • Deadline: September 30; applicable to group health plans that are subject to the Form 5500 filing requirement (and have not extended the Form 5500 deadline).

Medicare Part D notices

  • Deadline: October 14; applicable to group health plans that provide prescription drug coverage to individuals eligible for Medicare Part D.

Form 5500 (extended deadline for calendar year plans)

  • Deadline: October 15; applicable to employers with ERISA-covered group health plans that do not qualify for the small plan exemption (and have timely requested an extension to the filing deadline).

SAR (extended deadline for calendar year plans)

  • Deadline: December 15; applicable to group health plans that are subject to the Form 5500 filing requirement (if Form 5500 deadline was extended).

In addition to complying with annual compliance deadlines, employers must provide group health plan notices each year. Click here to see a listing of annual health plan notices.


At Creative Benefits Inc., it is our goal to guide you through ongoing change. Should you have any questions, please don’t hesitate to contact your Creative Benefits Team at 866-306-0200 or solutions@creativebenefitsinc.com.