The following checklist provides insurance agents/brokers, employers and benefits professionals a checklist of key upcoming dates and deadlines related to health benefits. This reminder list does not constitute all of the deadlines applicable to employers and some deadlines may be different based on variations in plan year or plan design.

Description

Date

Grace Period Amendment Deadline. If an employer wants to implement a grace period of up to 2-1/2 months for its Health Flexible Spending Arrangement (FSA) or Dependent Care FSA, it must do so before the end of its current plan year.

Some Debit Card Rules Go into Effect. Notice 2006-69 sets out requirements for auto-substantiation of expenses at merchants without health care-related merchant category codes. They must utilize an Inventory Information Approval System. These requirements go into effect for plan years that begin as of this date or later.

2007 Thresholds. Employers will want to make sure that all threshold increases are in place for 2007. This impacts high-deductible health plans (HDHPs), Health Savings Accounts (HSAs), Transportation Plans, and FSA/HRA mileage rates.

End of Grace Period. Typically, FSAs have grace periods of 2 months and 15 days.

HIPAA Privacy Notice Issuance. Employers with small group health plans ($5 million or less in annual receipts) must issue a Notice of Privacy Practices at least once every three years. The last required issuance was April 14, 2004.

Correction of Excess Contributions to HSAs. Employers may correct any contribution errors by the federal tax-filing deadline to avoid a 35% excise tax.