As the year progresses, employers offering group health benefits should take time to review upcoming midyear compliance responsibilities. Several federal laws—including ERISA, COBRA, and the No Surprises Act—require specific reporting and participant disclosures during the spring and summer months. Staying ahead of these obligations helps avoid penalties and ensures employees receive important information on time.
Below is a high-level overview of key requirements and deadlines for calendar-year plans:
Summary Plan Description (SPD) – New Enrollees
Group health plans subject to ERISA must provide a Summary Plan Description (SPD) to newly covered participants within 90 days of their coverage effective date.
For employees enrolled as of January 1, this means SPDs must be distributed by April 1. The SPD must also include applicable federal notices, such as the Newborns’ and Mothers’ Health Protection Act Notice.
Deadline: April 1, 2026
COBRA General Notice – New Enrollees
Employers subject to COBRA must provide a general notice outlining continuation rights to covered employees—and covered spouses, if applicable—within 90 days of coverage beginning.
For calendar-year plans, this requirement typically aligns with the April 1 timeframe.
Deadline: April 1, 2026
Prescription Drug Data Collection (RxDC) Reporting
Group health plans must annually report prescription drug and healthcare spending data to the Centers for Medicare & Medicaid Services (CMS).
Most employers rely on their carriers, third-party administrators, or pharmacy benefit managers to complete and submit this reporting, but it is important to confirm that responsibility has been assigned and completed.
Deadline: June 1, 2026
Form 5500 Filing
Employers sponsoring ERISA-covered group health plans may be required to file Form 5500 annually with the Department of Labor.
Certain plans may be exempt (generally those that are fully insured, unfunded, or a combination of both with fewer than 100 participants). For calendar-year plans, filings are due July 31, with an optional 2.5-month extension available via IRS Form 5558.
Deadline: July 31, 2026
PCORI Fees (Self-Insured Plans & HRAs)
Employers with self-insured medical plans—or certain Health Reimbursement Arrangements (HRAs)—must pay annual fees that fund the Patient-Centered Outcomes Research Institute (PCORI).
Notably, HRAs integrated with fully insured plans are still subject to these fees. Reporting and payment are completed via IRS Form 720.
Deadline: July 31, 2026
Additional Midyear Best Practices
Midyear is also an ideal time to step back and ensure your overall compliance strategy is on track. Employers should consider:
- Reviewing internal recordkeeping and documentation processes
- Confirming vendor responsibilities for reporting and filings
- Ensuring all required employee notices have been distributed properly
How We Support Our Clients
All Princeton HR Solutions clients have access to Mineral, which includes tools to create required compliance documents, distribute notices, and access live HR support. Employers can manage many of these requirements directly through the platform or connect with Mineral’s certified experts for guidance.
For employers who prefer a more hands-on approach, concierge-level support is also available. Please contact your Princeton HR representative for details.