It’s that time of year again! Some important compliance deadlines are coming up this fall and winter:
Medicare Part D Notices, October 14: Employers offering prescription drug coverage must issue the Notice of Creditable Coverage to individuals by October 14. Note: Employers may provide the notice any time during the 12 months preceding October 14.
Individual Exchange, December 15: Individuals must enroll in Marketplace/Exchange coverage for it to be effective January 1, 2020. Although the effective date is January 1, 2020, the enrollment for individuals has to be done during open enrollment for the individual exchange.
Special Open Enrollment Period for Small Groups, November 15, 2019 to December 15, 2019: The ACA requires carriers to offer a one month special open enrollment period (SEP) from November 15, 2019 to December 15, 2019 for a January 2020 effective date. The SEP is for groups that don’t have to meet contribution or participation requirements as long as they meet all other standard rules.
MLR Rebate Distribution, December 30: ERISA plan sponsors who received a Medical Loss Ratio (MLR) rebate on September 30 must pay the appropriate rebate amount to participants. If a plan sponsor paid the entire cost of the insurance, the employer could retain the entire rebate. The most common situation is when the plan sponsor and participants contribute toward the cost of coverage. In this case, the plan sponsor must determine the portions of the total plan cost contributed by both parties so the MLR rebate can be allocated among participants, plan costs, and the employer. Plan sponsors must first determine total participant contributions for the year used to calculate the MLR rebate. Current rebates are based on premiums paid to the carrier for the calendar year 2018.
Contact your LISI Regional Sales Manager for compliance support.