Determining a Health Plan’s Plan Year

Employer-sponsored health plans are subject to a variety of compliance requirements under federal law. Some of these requirements are linked to a health plan’s “plan year.” For example:

Health plan sponsors that provide prescription drug coverage to Medicare Part D eligible individuals must provide a disclosure notice to the Centers for Medicare & Medicaid Services (CMS) on an annual basis, within 60 days after the beginning of the plan year.

If a health plan is required to file a Form 5500, the deadline (without extensions) is the last day of the seventh month following the end of the plan year.

New legal requirements relating to health plans often take effect based on the planyear. For example, the cost-of-living adjustments for high deductible health plans (HDHPs) take effect at the beginning ofeach plan year.

It is important for an employer to identify its health plan’s “plan year” for purposes of monitoring its compliance obligations under federal laws. Also, a health plan’s summary plan description (SPD) must identify the plan year and the plan year must be included in the plan’s Form 5500 (if applicable).