Upcoming Employee Benefit Plan January and February Deadlines

January 27, 2017

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 January and February 2017 for calendar year plans:

January 16 – Deadline for the plan administrator of self-insured health plans to pay all or at least the first installment of the transitional reinsurance fee for 2016. To the extent a plan administrator has not submitted the form and payment, we recommend you do so now.

January 31 – Deadline for the plan sponsor to file Form 945 with the IRS to report income withheld during 2016 from distributions made to participants from qualified plans. (Note, if taxes were timely deposited with the IRS, the plan sponsor has an automatic extension until February 10, 2017, to file the Form 945.)

January 31 – Deadline for the payer to send Form 1099-R to participants, retirees and beneficiaries receiving distributions from qualified retirement plans in 2016.

January 31 – Deadline for the payer to send Form 1099-MISC to certain service providers or other recipients who received direct payments of $600 or more in 2016 from qualified retirement and health and welfare benefit plans for services, rent and specified other purposes.

January 31 – Deadline for employers to send employees Form W-2 (Wages and Tax Statement) for 2016. Also, submit such forms along with Form W-3 to the Social Security Administration.

January 31 – Deadline for plan sponsor (with an EIN ending in one or six) to file for an On-Cycle A determination letter for its individually designed qualified retirement plan.

February 1 – IRS new determination letter program opens for individually designed qualified retirement plans for plan sponsors who have “new” plans or plans that are terminating.

February 14 – Deadline (45 days after the close of a plan year) for the plan administrator to provide statements to participants in a defined contribution plan with participant-directed investments for the quarter ending December 31, 2016.

February 14 – Deadline (45 days after the close of the plan year) for the plan administrator to provide participants or beneficiaries in a defined contribution plan with participant-directed investments the required annual disclosures of specified plan information and specified investment-related information, such as fees deducted from the participant’s or beneficiary's account. 

February 28 – Deadline for the payer or the employer to file IRS Forms 1099-R and 1099-MISC with the IRS for 2016. Note that this deadline can be extended until March 31, 2017, if filed electronically.

February 28 – Deadline for Forms 1094-B and 1094-C transmittal forms for 2016 to be sent to the IRS, but this deadline is extended until March 31, 2017, if filed electronically. Note Forms 1095-B (Health Coverage) and 1095-C (Employer-Provided Health Insurance Offer and Coverage) must be provided to employees by March 2, 2017.

February 28 – Deadline for plan sponsor of group health plan that provides prescription drug coverage to Part-D eligible individuals to provide written disclosure to Centers for Medicare & Medicaid Services stating whether such drug coverage is, on average, at least as good as standard prescription drug coverage under Medicare Part D.  

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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