The paperwork, without the meeting.

Every Group

Four documents

1. The renewal letter. Whatever the carrier sent, in full, including the pages nobody reads.
2. The current plan summary. Deductibles, out-of-pocket maximums, copays and the network name, for every plan you offer.
3. The contribution split by tier. What the employer pays and what the employee pays, at each tier.
4. Enrolled counts by tier. How many people are actually in each tier today.

That fourth one is the one people guess at. Enrolled counts are what the rate is built on, so a guess there changes the answer.

If Your Group Is 50 or More

Two more

1. The census. Names, dates of birth, home zip, tier and plan election. Carriers quote and enroll on named individuals, so names are genuinely needed — Social Security numbers are not, at any size.
2. Claims experience with the last three renewals. At this size the carrier releases it, and asking for the last three rather than one is what makes a trend line possible instead of a single data point.

Everything in that list is protected health information and is handled that way. Documents stay in our systems; an NDA is available on request.

What Happens Next, and How Long It Takes

Assuming a complete file

• 2–50 employees — about seven days. Community-rated, so no claims data is needed and the read is fast.
• 51–250 employees — about fourteen days. Carrier questions about the last three renewals and claims are the routine path here, not an exception.
• 250 or more — up to three weeks.

Two clocks run at once: the carrier’s, which nobody controls, and ours, which starts the day the file is complete and turns around the day after proposals land.

Annual Filings and Returns

Plan-year driven

• Form 5500 — last day of the seventh month after the plan year ends. Extendable by two and a half months on Form 5558, which must be filed before the original deadline; the extension is not retroactive. ERISA plans, subject to the small-plan exemption.
• Summary annual report — nine months after the plan year closes, or two months after an extension ends. A distribution obligation, not a filing one.
• PCORI fee on Form 720 — 31 July of the year after the plan year ends. Self-funded sponsors, including level-funded plans and most HRAs.

Reporting to Employees and the IRS

Calendar-year driven

• 1095-C to individuals — 31 January, with an automatic 30-day extension. Or use the on-request model: post a conspicuous notice by the due date, retain through 15 October, and furnish within 30 days of a request. Several states run their own furnishing mandates that the federal relief does not override.
• 1094-C and 1095-C to the IRS — 28 February on paper, 31 March electronically. Electronic filing is mandatory at ten or more aggregate returns. Applicable large employers.

Notices with Their Own Clocks

Event-driven, not annual

• Part D creditable coverage — to individuals before 15 October each year, and to CMS within 60 days of the plan year start. No size exemption. This is the one small employers miss.
• COBRA — 30 days employer to administrator, 14 days administrator to qualified beneficiary. Then a 60-day election window, 45 days to the first premium and a 30-day grace period. Generally 20 or more employees. Michigan has no state continuation law, so a Michigan employer under 20 has no obligation at all.
• ICHRA notice — 90 days before the plan year begins. Employers offering an individual coverage HRA.

One thing deliberately left off: Section 125 non-discrimination testing has no final regulation behind its timing — only proposed rules from 2007. Treat it as practice rather than a deadline, and do not let anyone tell you otherwise.