As you question, “where did this month go already” remember to review this list of benefits deadlines. Thank you Isler Dare PC for providing this checklist for us to share.
By January 4
- Deadline for making minimum required contributions to single-employer defined benefit pension plans for Q1, Q2 and Q3 2020 that otherwise would have been made in 2020, but were delayed under the Coronavirus Aid, Relief, and Economic Security Act (CARES Act)
By January 15
- Post Schedule MB attachment from the 2019 Form 5500 (defined benefit pension plan actuarial information) on company intranet, assuming Form 5500 was filed by October 15, 2020
- Fund Q4 2020 contributions to defined benefit pension plans
By January 31
- Report value of health coverage on Form W-2
- Deadline for Massachusetts employers to distribute Form 1099-HC to satisfy requirements regarding state individual mandate
- Deadline for California employers to distribute ACA information returns (e.g., Form 1095-C) to individuals to satisfy requirements of the California state individual mandate
- Schedule quarterly meetings of Benefits Committee through December 31
- Review first payroll file to confirm new deductions have been accurately loaded into internal systems (e.g., 401(k) deferrals and health and welfare plan premiums and deductions), and review payroll configuration to confirm it conforms to retirement plan definition of pay
- Confirm contracts for all benefit providers have been signed, including insurance policies, administrative service agreements, and HIPAA[i] business associate agreements
- Update company intranet with new benefit plan documents, Summary Plan Descriptions, Summaries of Material Modifications, policies, and forms
- Provide information in response to annual compliance questionnaires or other requests for information from retirement plan recordkeepers
- Continue tracking data to satisfy ACA reporting obligations for 2021 (which will be due in 2022) regarding offers of affordable, minimum essential coverage to FTEs
- Work with retirement plan recordkeepers to perform nondiscrimination testing, including 410(b) minimum coverage testing, 402(g) limit testing, 401(k) and 401(m) ADP/ACP[ii] testing, 415 limit testing, 414(s) compensation testing, and top-heavy testing for 2020 plan year
- Begin tracking part-time employees, as those who complete at least 500 hours over the next three years must be eligible to make elective deferrals into a 401(k) plan under the SECURE Act
[i] HIPAA – Health Insurance Portability and Accountability Act of 1996
[ii] ADP/ADC – Actual Deferral Percentage and Actual Contribution Percentage
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