Late June is when competent benefits teams put July 31 on the whiteboard in large letters.

Form 5500

Many ERISA welfare plans file Form 5500 by July 31 for calendar plan years (extensions exist if you file Form 5558 on time). Small unfunded or fully insured welfare plans may be exempt from filing — but self-insured medical plans and arrangements that look “too small to worry about” still get people in trouble when assumptions were wrong.

PCORI fees

Self-insured plans, including certain HRAs, owe the Patient-Centered Outcomes Research Institute fee, reported on Form 720, generally due July 31 of the year following the plan year end. If you have an HRA beside a fully insured medical plan, don’t assume someone else paid PCORI for the HRA portion.

This week’s punch list

  1. Confirm who files 5500s — broker, TPA, CPA, or “we thought the carrier did it.”
  2. Confirm average participant counts for PCORI calculations.
  3. Calendar any extension strategy before you need it.

Compliance calendars aren’t exciting. Penalty letters are worse.