Upcoming Employee Benefit Plan Deadlines

February 26, 2016

This client alert follows up on our prior alerts entitled "Employee Benefit Plan Filing Deadlines." The following are the most common applicable filing deadlines (and/or "Heads Up" for coming deadlines) or other important dates for March and April 2016 for calendar year plans:

March 1 - Deadline for existing multiple employer welfare arrangements (MEWAs) to file Form M-1 for 2015 with the Employee Benefits Security Administration. 

March 1 - Deadline for a plan sponsor of a health and welfare plan that provides prescription drug coverage to Medicare Part D eligible individuals to report to the Centers of Medicaid and Medicare Services whether such coverage is creditable coverage.

March 15 - Deadline for a plan administrator of a 401k plan to distribute excess contributions and related earnings from 2015 to prevent 10 percent excise tax on the employer. Note this does not apply to 401k plans with eligible automatic contribution arrangements.

March 15 - Deadline for employer contributions to be made a qualified retirement plan trust in order for the employer to get a tax deduction for such contributions for 2015. Note this deadline is extended if the deadline for filing the employer’s corporate tax return is extended.  

March 30 - Deadline for a plan administrator of qualified plans and health and welfare plans to provide a summary plan description and any summary of material modifications to an individual who became a participant on January 1, 2016. (Note: General deadline is within 90 days of becoming a new participant in a plan or, for beneficiaries, within 90 days after first receiving benefits.)

March 30 - Deadline for a plan administrator of a health and welfare plan to provide a general COBRA notice to participants and spouses who became a became a participant on January 1, 2016. (Note: General deadline is within 90 days of becoming a new participant in a plan.)

March 31 - Original deadline for large employers to file a copy of the Forms 1094-C with the IRS if filing electronically. Note this date has been extended to June 30, 2016. See our December 31, 2015, alert.

March 31 - Original deadline for small employers who provide a self-insured health plan (or health insurance carriers if the plan is insured) for employees to file a copy of the Forms 1094-B with the IRS if filing electronically. Note this deadline has been extended to June 30, 2016. See our December 31, 2015, alert.

March 31 - Deadline for an employer or other payer to file IRS Forms 1099-R and 1099-MISC with the IRS, if filed electronically.

April 1 - Deadline for a plan administrator of a qualified retirement plan to distribute any minimum required distribution to any participant who has terminated employment and reached age 70-1/2 or older in 2015. Note this could apply to a five percent owner of the employer sponsoring the plan regardless of whether the owner has terminated employment.

April 14 - Deadline for the contributing sponsor and each member of such sponsor’s controlled group to file an annual financial and actuarial information notice (Form 4010) with the PBGC of a defined benefit pension plan’s funding status if the FTAP of any such plan in the controlled group is less than 80 percent. (Note: General deadline is the 105th day after the filer’s fiscal year or calendar year, if controlled group members have different fiscal years.)

April 15 - Deadline for a 401k plan to distribute a participant’s deferrals in 2015 which exceeded the Internal Revenue Code Section 402(g) limit, which for 2015 was $18,000.

April 29 - Deadline (120 days after the end of the plan year) for the plan administrator of a defined benefit pension plan to provide an annual funding notice to the PBGC, each plan participant and beneficiary, each labor organization representing such participants or beneficiaries and, in the case of a multiemployer defined benefit pension plan, each employer that has an obligation to contribute to such plan.

Please note that there are other deadlines which apply to the distribution of documents and notices to employees upon their employment or their termination of employment which are not addressed in this alert. If you have any questions regarding the deadlines listed in this alert or any other compliance deadlines, please contact Donald S. Kohla at 678.336.7140 or Jan G. Marsh at 678.336.7135.

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