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February 10, 2020

Annual Health Plan Reporting Reminders

MEWA Reporting - 2019 Form M-1

If you sponsored a multiple employer welfare arrangement (MEWA), including an association health plan in 2019, make certain that you file the 2019 Form M-1 annual report by March 1, 2020.  This form is intended to ensure that such plans are complying with the Affordable Care Act, the Health Insurance Portability and Accountability Act, and other federal related laws.  Failure or refusal to file a completed or accurate Form M-1 could result in penalties of up to $1,625 per day (indexed, beginning January 15, 2020).  As a reminder, the Form M-1 can only be submitted electronically through the DOL’s Online Filing System (http://www.askebsa.dol.gov/mewa).  In addition, plans required to file a Form M-1 must also file the Form 5500 regardless of plan size or type of funding. 

Annual Reporting Reminder - Medicare Part D Disclosure Notice to CMS

All group health plans, whether insured or self-funded, are required to provide notices of creditable or non-creditable coverage to the Centers for Medicare and Medicaid Services (CMS) on an annual basis. The Creditable Coverage Disclosure Form filing must be accomplished electronically, and is due within 60 days of the commencement of the plan year. For calendar year plans, this means the disclosure filing must be accomplished no later than March 1, 2020. In addition, this disclosure form must be completed within 30 days upon other events such as when the prescription drug benefit is cancelled, or if any material change in the prescription drug benefits that would cause it to change status from creditable to non-creditable, or vice versa.  CMS provides both guidance and instructions, as well as access to the disclosure form on its website.

The information contained in this article is provided as general guidance and may be affected by changes in law or regulation. This article is not intended to replace or substitute for accounting or other professional advice. Please consult a CBIZ professional. This information is provided as-is with no warranties of any kind. CBIZ shall not be liable for any damages whatsoever in connection with its use and assumes no obligation to inform the reader of any changes in laws or other factors that could affect the information contained herein.

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