Given that 2020 was a year when everything changed, and protocols and deadlines were rewritten, extended or both, plan providers can’t take anything for granted here in the new year. Add a new presidential administration to the landscape and now, absolutely nothing seems written in stone.
With so many touchpoints and timelines changed last year, be careful, however, not to be lulled into thinking that deadline extensions and good-faith forgiveness are the new “norm”.
The dates below provide a quick reminder, courtesy of Isler Dare PC, of a few important benefit deadlines that are firm, regardless of anything else that may presently be in flux.
February Benefit Deadlines Checklist
By February 1
- Confirm 401(k)/403(b) plan recordkeepers have provided Q4 2020 quarterly statements to participants, including fee disclosure information (deadline is February 14)
- Confirm retirement plan recordkeepers have provided Forms 1099-R to participants who received retirement plan distributions in 2020
- File Form 945 to report income tax withheld from retirement plan distributions in 2020
- If contributions to a defined benefit pension plan were delayed in 2020 under the CARES Act[i], file amended 2020 premium filing with the PBGC (pension benefit guaranty corporation[ii])
By February 10
- Complete comparative analysis to document compliance with nonquantitative treatment limitations under the Mental Health Parity and Addiction Equity Act, as required under the Consolidated Appropriations Act, 2021 (“CAA-21[iii]”)
By February 28
- Confirm retirement plan recordkeepers have filed Forms 1099-R (due March 31 if filing electronically)
- File PBGC Form 1-ES estimated premium payment (flat-rate premium for defined benefit pension plans with over 500 participants)
- File 2020 ACA[iv] information returns (Forms 1094-C and 1095-C) with IRS if not filing electronically
- Work with FSA/125 plan recordkeepers or brokers to perform applicable nondiscrimination testing, including 105(h) testing, 125 testing, and 129 testing for 2020 and projected testing for 2021
- Hold quarterly meeting of Benefits Committee to review 2020 year-end investment performance, fees, plan administration data, and plan operational issues
[i] Coronavirus Aid, Relief, and Economic Security Act https://home.treasury.gov/policy-issues/cares
[ii] Pension Benefit guaranty Corporation https://www.pbgc.gov/
[iii] Consolidated Appropriations Act https://www.onedigital.com/blog/consolidated-appropriations-act-2021/
[iv] Affordable Care Act https://www.healthcare.gov/glossary/affordable-care-act/
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