2017 Compliance Calendar

Keeping You Up-to-Date!

This Compliance Calendar was created by Vita to help you identify important benefit due dates for health, welfare and retirement plans.
The calendar includes dates involving:

    Notice distributions 
    Plan disclosures
    Dates for various plan-related regulatory filings

This calendar is based on a January 1st - December 31st ERISA Plan Year and a January 1st contract renewal date.
Some compliance dates are subject to change for companies not on this schedule.
 

Select a Month:

JAN     FEB     MAR   |   APR     MAY     JUN   |   JUL     AUG     SEP   |   OCT     NOV     DEC

JANUARY 2017

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Plan Date Description
Welfare 1/1 ERISA Plan Year commences
Retirement 1/1 Plan Year commences
Welfare 1/1 Welfare plan and Section 125 contract years begin
Welfare 1/1 SF HCSO – Deadline to submit Q4 SF HSCO expenditures, as applicable (companies with 20+ employees doing business in SF; Non-profits with 50+ employees)
Welfare 1/1 Distribute Summary Plan Description (SPD); includes various annual notifications (e.g. Medicare Part D Creditability)
Welfare 1/1 Distribute Summary of Benefits and Coverage (SBC) (date may change based on benefits plan renewal date)
ACA 1/17 First Transitional Reinsurance Program contribution due for prior plan year via www.pay.gov; may be full or partial payment (self-funded plans only)
Retirement 1/31 Census Deadline – Deadline to submit census data, ownership, and year-end questionnaire to Service Provider for discrimination testing
Retirement 1/31 Form 1099-R Deadline – Deadline to send Form 1099-R to participants for distributions during the previous calendar year (Service Provider)
Welfare 1/31 W-2 delivery deadline.  Aggregate cost of health coverage must be included (for employers with more than 250 W-2s)

FEBRUARY 2017

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Plan Date Description
Retirement Mid-Feb Discrimination tests performed and any necessary distribution calculations for failed discrimination tests, excess employer contributions, and excess employee contributions are reported
Welfare 2/15 Annual Report for Self-Insured Voluntary Plan Transactions DE 2568V (for CA VDI Plans Only)
Welfare 2/28 Deadline to file non-electronic 1094-C and 1095-C with IRS  (companies with 50+ full time equivalent employees)
Welfare 2/28 or 3/1 Medicare Part D Credibility – Deadline to notify CMS of Medicare Part D Credibility Status for current plan year (Disclosure Form)


MARCH 2017

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Plan Date Description
Welfare 3/2 Deadline to mail 1095-C to employees (companies with 50+ full time equivalent employees)
Retirement 3/15 ADP/ACP Refunds – Deadline to make corrective distributions for failed discrimination test and avoid 10% excise tax penalties
Retirement 3/15 Form 5330 – Deadline to file Form 5330 for excise tax on failed ADP/ACP test
Welfare 3/31 Deadline to electronically file 1094-C and 1095-C  (companies with 50+ full time equivalent employees)



APRIL 2017

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Plan Date Description
Welfare 4/1 SF HCSO – Deadline to submit Q1 SF HSCO expenditures, as applicable (companies with 20+ employees doing business in SF; Non-Profits with 50+ employees)
Retirement 4/1 Required Minimum Distribution – Deadline to take first Required Minimum Distribution (RMD) for participants attaining age 70 ½ or retiring after 70 ½ in prior calendar year
Retirement 4/15 Excess Contribution Refunds – Deadline to return excess retirement plan deferrals for the previous Plan Year
Welfare 4/30 SF HCSO – Deadline to complete SF HCSO Annual Reporting Form
Retirement 4/30 For large 5500 filers, time to select auditor and schedule annual audit
Section 132 4/30 San Francisco Commuter Benefits Ordinance - compliance online reporting (employers between 20+ employees with at least 1 employee working in SF)
Section 132 4/30 Bay Area Commuter Ordinance - compliance reporting (employers with 50+ employees in the 9 Bay Area counties)

MAY 2017

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Plan Date Description
    No Items








JUNE 2017

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Plan Date Description
Section 125 Mid-Apr
to
Mid-Jun
Discrimination testing conducted
Retirement 6/30 Eligible Automatic Contribution Arrangement (EACA) – For plans with EACA, corrective distributions for failed ADP/ACP tests must be made to participants within 6 months after the Plan Year end
   


JULY 2017

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Plan Date Description
Welfare 7/1 SF HCSO – Deadline to submit Q2 SF HSCO expenditures, as applicable (companies with 20+ employees doing business in SF; Non-Profits with 50+ employees)
Welfare, Retirement, & Section 125 7/31 Deadline for filing Form 5500 or Form 5558 (5500 filing extension to October 15th)
ACA 7/31 Patient-Centered Outcomes Research Trust Fund Fee (PCORI) - Deadline to submit fees via Form 720 and paid through EFTPS (self-funded employers)


AUGUST 2017

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Plan Date Description
Retirement 8/1 Interim ADP/ACP Testing for 401(k) plans










SEPTEMBER 2017

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Plan Date Description
Welfare & Retirement 9/30 Deadline for distributing the Summary Annual Report (SAR) unless an extension was filed for the Form 5500 in July









OCTOBER 2017

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Plan Date Description
Welfare 10/1 SF HCSO – Deadline to submit Q3 SF HSCO expenditures, as applicable (companies with 20+ employees doing business in SF; Non-Profits with 50+ employees)
Retirement 10/1 Annual Notices – First day to distribute the following notices to Plan participants (no earlier than today):
- Qualified Default Investment Alternative

- Safe Harbor Notice
- Automatic Contribution Arrangement Notice
Welfare & Retirement 10/15 Extension deadline for filing Form 5500
Welfare 10/15 Medicare Part-D Creditable Coverage Disclosure Deadline (Notice Included in SPD)


NOVEMBER 2017

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Plan Date Description
Retirement 11/1 Participant Fee Disclosures – Confirm that participant fee disclosures have been or will be distributed to Plan participants by end of year
ACA 11/15 Second Transitional Reinsurance Program contribution due for prior plan year, if contribution is scheduled for two payments (self-funded plans only)


DECEMBER 2017

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Plan Date Description
Retirement 12/1 Annual Notices – Deadline to provide following notices to Plan participants (no later than today):
- Qualified Default Investment Alternative
- Safe Harbor Notice
- Automatic Contribution Arrangement Notice
Welfare & Retirement 12/15 Deadline for distributing the Summary Annual Report (SAR) if an extension was filed for the Form 5500
Welfare 12/31 End of ERISA Plan Year
Retirement 12/31 Deadline for depositing any accrued Safe Harbor Contributions for the prior year

ONGOING THROUGHOUT YEAR

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Hire Date Distribute Exchange Notice

Date Benefits Eligible COBRA Initial Notice*
Welfare Plan Summary Plan Description (SPD)*
Summary of Benefits and Coverage (SBC)† 
Certificates of Coverage*
HIPAA Privacy Notice (for employers with full access to PHI)

Monthly Audit carrier bills, Section 125 Deduction Reports, and COBRA transmittal for accuracy

Termination Date Distribute COBRA Election Notice Packet for all COBRA eligible coverage and conversion and portability information for life insurance policies

Compliance Docs Maintained by Employer Premium Only Plan Document
ERISA Welfare Benefits Plan Document
Cafeteria Plan Document
Retirement Plan Document
HIPAA Privacy and Security Policy

Required Disclosures Included in the Vita Welfare SPD ACA Pre-existing Conditions
ACA Choice of Primary Care Provider
ACA External Claims Review ACA Rescission of Coverage
ACA Medical Loss Ratio Rebates
ACA Grandfathering Status 
HIPAA Special Enrollment Rights
HIPAA Continuity of Coverage
HIPAA Claims Appeals
Variable Hour Employee Eligibility
Newborns and Mothers Health Protection Act of 1996
Women’s Health and Cancer Rights Act
Mental Health Parity Act
Mental Health Parity and Addiction Equity Act
Qualified Medical Child Support Orders (QMCSO) Provision
Children’s Health Insurance Program (CHIP) Reauthorization Act of 2009
FMLA Rights of Coverage Continuation
USERRA Rights of Coverage Continuation
Medicare Part D Prescription Coverage

* COBRA Initial Notices, SPDs and Certificates of Coverage are required to be distributed within 90 days of benefits eligibility, but Vita recommends that this document be distributed prior to the benefits eligibility date, if possible.

† HIPAA Privacy Notes and SBCs are required to be distributed at the time of the individual's enrollment in the plan.  Vita recommends distribution of these documents with the initial enrollment paperwork packet.

‡  All compliance documents and disclosures that are not associated with a specific date are subject to varying initial and ongoing notification requirements. For more information regarding the timing requirements of these documents and notices, please contact your Vita representative.
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