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Message 1 Federal Benefit Compliance Calendar for 2025

2 Table of Contents Table of Contents .....................................................................................................................................................2 Calendar ....................................................................................................................................................................3 Appendix – Variable Due Dates for Non-Calendar Year Plans ............................................................................6 Medicare Part D Disclosures (Due 60 days after the start of the plan year) ..........................................................6 5500 Reporting (Due the last day of the 7th month after the end of the plan year): ..............................................6 Summary of Material Modifications (Due within 210 days after end of plan year) .................................................7 Summary Annual Report (SAR) (Due within 9 months after end of the plan year) ................................................7 This calendar highlights important compliance due dates for employee health and welfare benefits. NOTE: Compliance due dates that are tied to a plan year assume a calendar year plan. Actual due dates may differ for some items if the employer’s plan runs on a non-calendar year. Please see the Appendix for variable due dates in 2025-2026 for certain reporting requirements tied to plan year rather than calendar year. The Summary of Benefits & Coverage (SBC) and other notices must be distributed annually during the employer’s open enrollment. These notices are not addressed in the calendars below. For more information on these notices, see our Notices and Disclosures Guide. While every effort has been taken in compiling this information to ensure that its contents are totally accurate, neither the publisher nor the author can accept any liability whatsoever for any inaccuracies or changed circumstances of any information herein or for the consequences of any reliance placed upon it. This publication is distributed on the understanding that the publisher is not engaged in rendering legal, accounting, or other professional advice or services. Readers should always and without exception seek professional advice before entering into any commitments.

3 Calendar Month Requirement Due Date Description January W-2s Jan 31 Employers that filed at least 250 W-2s in the previous year must report the cost of coverage (employer and employee) in Box 12 (Code DD). Employers must report all employer contributions to employees’ HSAs in Box 12 of Form W-2, using code W. Employers must report dependent care benefits paid or incurred in Box 10 of Form W-2. Amounts over $5,000 ($2,500 in the case of a separate return filed by a married individual) are also included in Box 1. March Part D Creditable Coverage Report due to CMS (for calendar year plans*) Mar 1 Employers sponsoring prescription drug plans must report to CMS within 60 days after the beginning of the plan year regardless of whether the coverage is creditable. *See Appendix for due dates for non-calendar year plans. HIPAA Breach Notifications due to OCR Mar 1 Employers sponsoring group health plans must report any breach of Protected Health Information (PHI) affecting fewer than 500 individuals to OCR within 60 days of the end of the calendar year (regardless of when the plan year ends). 1095-B and 1095-C forms due to individuals Mar 3 Applicable Large Employers must provide offer of coverage information to employees (copies of 1095-Cs). Employers with self-funded plans must provide coverage information to covered individuals (copies of 1095-Bs or 1095-Cs). In addition, employers must comply with state-level requirements to provide Form 1095s (or 1099-HCs) to covered individuals residing in California, New Jersey, Rhode Island, and the District of Columbia. See our State Individual Mandate Employer Reporting Guide.

4 1094-B, 1095-B, 1094-C, and 1095-C Forms due to IRS (if filing electronically) Mar 31 Applicable Large Employers and Employers with self-funded plans must report offer and coverage information to the IRS as required under §§6055 and 6056. NOTE: When reporting for the 2024 calendar year, almost all employers filing 10 or more tax forms (e.g., 1095s, W-2s, 1099s) must report electronically. April Last day for 2024 HSA contributions or corrections Apr 15 Employers and individuals have until the tax filing deadline to make HSA contributions and corrections for a given calendar year. June Prescription Drug Reporting Jun 1 Due date for reporting data for the 2024 calendar year. July Last day to issue a Summary of Material Modification (SMM) for the prior plan year (for calendar year plans*) Jul 29 ERISA requires that a Summary of Material Modification (SMM) be issued any time there is a change in a plan provision that is “material” (but not a reduction) or any time there is a change in a plan provision that is required to be in the Summary Plan Description (SPD). The due date is 210 days after the end of the plan year to which the change applies. *See Appendix for due dates for non-calendar year plans. NOTE: For a material reduction, an SMM is required within 60 days of the adoption of the change. PCORI Fee Jul 31 Patient-Centered Outcomes Research Institute (PCORI) fee is due for policy or plan years that ended in 2024. 5500 Filing (for calendar year plans*) Jul 31 Employers must file 5500s for plans with at least 100 participants (i.e., employees) at the start of the plan year. In addition, employers with plans that have fewer than 100 participants must file a 5500 if the plan is “funded” (i.e., the assets of the plan are segregated from the general assets of the plan sponsor through a trust). *See Appendix for due dates for non-calendar year plans September Summary Annual Report (SAR) (for calendar year plans*) Sept 30 A summary annual report (SAR) is a summary of the Form 5500. A SAR is required for any plan subject to Form 5500 filing, except for self-insured plans without any segregation of assets in a trust or otherwise (unfunded). It is due within 9 months of the close of the plan year. *See Appendix for due dates for non-calendar year plans

5 October Medicare Part D Creditable Coverage Notices to Individuals Oct 14 Employers offering prescription drug coverage must issue the Notice of Creditable/Non-creditable Coverage to individuals by October 14 (employers may provide the notice at any time during the 12 months preceding October 15 – e.g., during the previous open enrollment). 5500 Filing Due Date with Extension (for calendar year plans*) Oct 15 Employers must file 5500s for plans with at least 100 participants (i.e., employees) at the start of the plan year. In addition, employers with plans that have fewer than 100 participants must file a 5500 if the plan is “funded” (i.e., the assets of the plan are segregated from the general assets of the plan sponsor through a trust). *See Appendix for due dates for non-calendar year plans December Summary Annual Report with Extension (SAR) (for calendar year plans*) Dec 15 A summary annual report (SAR) is a summary of the Form 5500. A SAR is required for any plan subject to Form 5500 filing, except for self-insured plans without any segregation of assets in a trust or otherwise (unfunded). It is due within 9 months of the close of the plan year. *See Appendix for due dates for non-calendar year plans Last day for employer to distribute portion of MLR rebate that is considered plan assets Dec 29 Employers sponsoring fully-insured group health plans must distribute the portion of an MLR Rebate that is considered plan assets within 90 days of receipt (i.e., for rebates received September 30, by December 29). Otherwise, the employer may be subject to ERISA trust requirements. Gag Clause Attestations Dec 31 Employers and carriers must submit an attestation of compliance with the gag clause prohibition contained in the Consolidated Appropriations Act (CAA).

6 Appendix – Variable Due Dates for Non-Calendar Year Plans Medicare Part D Disclosures (Due 60 days after the start of the plan year) Plan Year Beginning Medicare Part D Creditable Coverage Reporting Due to CMS December 1, 2024 January 29, 2025 January 1, 2025 March 1, 2025 February 1, 2025 April 1, 2025 March 1, 2025 April 29, 2025 April 1, 2025 May 30, 2025 May 1, 2025 June 29, 2025 June 1, 2025 July 30, 2025 July 1, 2025 August 29, 2025 August 1, 2025 September 29, 2025 September 1, 2025 October 30, 2025 October 1, 2025 November 29, 2025 November 1, 2025 December 30, 2025 5500 Reporting (Due the last day of the 7th month after the end of the plan year): Plan Year Ending 5500 Due Due Date with Extension June 30, 2024 January 31, 2025 April 15, 2025 July 31, 2024 February 28, 2025 May 15, 2025 August 31, 2024 March 31, 2025 June 15, 2025 September 30, 2024 April 30, 2025 July 15, 2025 October 31, 2024 May 31, 2025 August 15, 2025 November 30, 2024 June 30, 2025 September 15, 2025 December 31, 2024 July 31, 2025 October 15, 2025 January 31, 2025 August 31, 2025 November 15, 2025 February 29, 2025 September 30, 2025 December 15, 2025 March 31, 2025 October 31, 2025 January 15, 2026 April 30, 2025 November 30, 2025 February 15, 2026 May 31, 2025 December 31, 2025 March 15, 2026

7 Summary of Material Modifications (Due within 210 days after end of plan year) Plan Year Ending SMM Due June 30, 2024 January 26, 2025 July 31, 2024 February 26, 2025 August 31, 2024 March 29, 2025 September 30, 2024 April 28, 2025 October 31, 2024 May 29, 2025 November 30, 2024 June 28, 2025 December 31, 2024 July 29, 2025 January 31, 2025 August 29, 2025 February 28, 2025 September 26, 2025 March 31, 2025 October 27, 2025 April 30, 2025 November 26, 2025 May 31, 2025 December 27, 2025 Summary Annual Report (SAR) (Due within 9 months after end of the plan year) Plan Year Ending SAR Due April 30, 2024 January 31, 2025 May 31, 2024 February 28, 2025 June 30, 2024 March 31, 2025 July 31, 2024 April 30, 2025 August 31, 2024 May 31, 2025 September 30, 2024 June 30, 2025 October 31, 2024 July 31, 2025 November 30, 2024 August 31, 2025 December 31, 2024 September 30, 2025 January 31, 2025 October 31, 2025 February 29, 2025 November 30, 2025 March 31, 2025 December 31, 2025