The deadlines do not send reminders. We do.
Most benefits compliance failures are not decisions. They are dates that passed while somebody was busy. Almost all of them run off your plan year rather than the calendar, which is exactly why they get missed. Below is what a plan year actually obliges you to do, and which of it we carry.
Stated as rules, because that is how they are written.
Each deadline below is expressed the way the regulation expresses it — relative to your plan year — with the calendar-year plan date in brackets. Which ones apply depends on your size and funding model.
Form 5500
Last day of the seventh month after your plan year ends. [Calendar-year plan: 31 July.] A Form 5558 extension buys up to two and a half months more [15 October], but it has to be filed on or before the original due date.
ERISA welfare plans. Exempt if fewer than 100 participants at the start of the plan year and unfunded, fully insured, or a combination. Funded through a trust and you file at any size.
We can help you with the filing →
ACA compliance for Michigan employers, from offers to filings →
Summary Annual Report
Within nine months after the plan year closes [30 September]. If the 5500 was extended, within two months after the extension period ends [15 December].
Not required if the plan is exempt from filing the 5500. Totally unfunded welfare plans are exempt.
Furnishing Forms 1095-C
31 January, plus a permanent automatic 30-day extension, so about 2 March. No further extension exists. See “What changed” below: you may now be able to post a notice instead of mailing.
Applicable large employers. Always calendar-year based. This one never follows your plan year.
Filing 1094-C and 1095-C
28 February on paper, 31 March electronically (next business day if that falls on a weekend or holiday).
Electronic filing is mandatory once you file 10 or more information returns in aggregate, W-2s, 1099s and 1095s counted together. In practice that is nearly every applicable large employer.
Part D Notice to Employees
Annually, before 15 October, ahead of Medicare’s annual enrollment window. Also at initial eligibility, at the coverage effective date, on any change in creditable status, and on request.
Any employer offering prescription drug coverage. A fixed calendar date, not a plan-year one.
Part D Disclosure to CMS
Within 60 days after your plan year begins, within 30 days of terminating drug coverage, and within 30 days of any change in creditable status.
Filed online with CMS. This one does run off your plan year, which is why it is the more commonly missed of the two.
Retiree Drug Subsidy Reconciliation
Within 15 months after the end of the plan year, or a longer limit CMS specifies, the sponsor submits actual costs and CMS adjusts that year’s payments.
Only for employers taking the Part D retiree drug subsidy. A determination can be reopened at the sponsor’s request within a year for any reason, and up to four years where there is new evidence or an error in the computation.
PCORI Fee, Form 720
31 July of the calendar year following the last day of your plan year. A plan year ending 31 January 2026 is therefore not due until 31 July 2027.
Sponsors of self-insured plans, including level-funded plans and most HRAs. If you are fully insured the carrier pays it, but a fully insured plan with an HRA alongside means you owe it on the HRA.
Summary of Benefits and Coverage
No later than 30 days before the first day of the new plan year at renewal. With enrollment materials otherwise, within 90 days for special enrollees, and within seven business days on request.
A mid-year material change not already reflected in the SBC needs notice at least 60 days before it takes effect.
CHIP Notice
Annually, to employees in states that offer Medicaid or CHIP premium assistance, whether or not they are enrolled in your plan.
The regulation says only “annually”; the practical answer is to send it with open enrollment materials so it has a fixed home in the year.
RxDC Prescription Drug Reporting
1 June each year, covering the previous calendar year. Plan-level spending on prescription drugs and on medical claims, filed to CMS through the Health Insurance Oversight System.
Group health plans of every size, insured and self-funded. Your carrier, TPA or PBM files most of the data. The plan-level file is the one that gets missed, because nobody else can produce it.
Gag Clause Attestation
31 December each year. An attestation that nothing in your contracts with a network, a TPA or a provider stops you from seeing your own claims and cost data.
Group health plans of every size, insured and self-funded. A carrier or TPA may submit for you. Get that in writing, the attestation is the plan’s obligation, not theirs.
Every federal penalty behind these deadlines, in one table →
Rules hold still. Numbers do not.
These are the current figures as of October 18, 2026. Dollar limits are indexed every year, so confirm any figure against the agency source before relying on it. Where the 2027 number is already published we have put it alongside, because most of the renewals being quoted right now straddle both years.
ACA Affordability
9.96% of household income. The most an employee can be asked to pay for self-only coverage before your offer stops counting as affordable. For plan years beginning in 2027 it rises to 10.22%.
Price against a safe harbor you can actually see (W-2, rate of pay or federal poverty line), not household income you will never know.
Employer Mandate Penalties
$3,340 and $5,010 per full-time employee, per year. The first if you offer nothing to substantially all full-time employees. The second if the offer is unaffordable or fails minimum value.
The first counts every full-time employee less the first thirty. The second counts only the ones who took a subsidy on the Marketplace.
ACA Out-Of-Pocket Maximum
$10,600 self-only, $21,200 family. The ceiling on in-network cost sharing for essential health benefits. For 2027: $12,000 and $24,000.
This is not the HDHP limit below, and the two are not interchangeable. A plan can clear one and fail the other.
HDHP Limits
$1,700 and $3,400 minimum deductible. $8,500 and $17,000 maximum out-of-pocket. What a plan has to look like before an HSA is allowed to sit next to it.
Self-only first, family second. Embedded deductibles are where family plans usually break the test.
HSA Contributions
$4,400 self-only, $8,750 family, plus the $1,000 catch-up from age 55.
Catch-up is per account holder. A couple both over 55 need two accounts to use both.
Health FSA
$3,400, with up to $680 carrying into the next year.
Carryover and a grace period are alternatives, not a pair. A general-purpose carryover also blocks HSA eligibility into the following year.
PCORI Fee
$3.84 per covered life for plan years ending between 1 October 2025 and 30 September 2026. The band before it was $3.47.
Self-funded and level-funded plans pay it themselves on Form 720. On a fully insured plan the carrier pays it and you do not file.
Excepted-Benefit HRA
$2,200 for the plan year. The standalone account you can fund for someone who declines your plan.
Useful where a spouse’s plan is the better buy and you still want to put money behind the employee.
Half of this list does not apply to you.
Employer headcount is what switches most of these obligations on, and the thresholds do not line up neatly. Here is roughly where each band sits.
Below the Mandate, Not Below the Rules
Under 50 full-time and full-time-equivalent employees you are not an applicable large employer: no employer mandate and no 1094-C or 1095-C filing. Federal COBRA begins at 20 employees, the same threshold in every state. Michigan has no state mini-COBRA law behind it, so a Michigan employer under 20 has no statutory continuation obligation of its own. Conversion to an individual policy may still be available under some insured contracts, so check the certificate. ERISA plan documents, SBCs, and the Part D and CHIP notices apply from your very first plan, at any size.
The year you cross fifty is the year it changes
Crossing 50 full-time equivalents makes you an applicable large employer: the employer mandate and 1094-C/1095-C reporting begin, measured on the prior calendar year, so the obligation arrives a year after the growth did. Form 5500 follows once the plan reaches 100 participants, counted as covered employees, not dependents.
Self-Funding Brings Its Own Filings
At this size self-funding becomes the common answer, including level funded, which is self-funded up to the attachment point however much the invoice looks like a premium. It carries obligations a fully insured employer never sees: the PCORI fee on Form 720, owed by you rather than the carrier, and Section 105(h) non-discrimination testing on the plan. Multi-site payrolls also start to complicate eligibility data.
More Vendors, More Documents
Carve-outs mean several arrangements, each with its own plan document, disclosures and reporting. Populations spread across states pick up state leave and continuation rules that do not follow your head office, and fiduciary process stops being informal.
Michigan Auto Insurance Letter: What Opting Out Gains and Gives Up
The filing most employers assume does not apply to them.
Every ERISA welfare plan is in scope unless it qualifies for the small-plan exemption. Two things decide it, and the second one is where the language gets confusing.
Do you have to file?
You are exempt only if both are true: fewer than 100 participants at the start of the plan year, and benefits paid from the employer’s general assets or through an insurance contract rather than through a trust.
Miss either condition and you file, at any headcount.
“Funded” Does Not Mean What It Usually Means
In everyday benefits language a plan is fully insured or self-funded. ERISA uses the word differently: a plan is “funded” when its assets sit in a trust.
So a fully insured plan and a self-funded plan paid from general assets are both unfunded for this test, and both can use the exemption. Put a trust in place and the exemption disappears regardless of size.
Level funded counts as self-funded. The invoice arrives looking like a fully insured premium, but the employer is funding claims up to an attachment point with stop-loss above it, which is why level-funded plans get classified wrongly more often than any other kind.
Who Counts as a Participant
Covered employees, not their dependents. A plan covering 80 employees and 140 dependents is at 80, not 220.
Count it at the start of the plan year. Crossing 100 mid-year does not pull you in until the following year.
When It Is Due
Last day of the seventh month after the plan year ends [calendar-year plan: 31 July]. Form 5558 extends it by up to two and a half months [15 October], but it has to be filed on or before the original due date. You cannot extend retroactively.
The SAR Follows It
A Summary Annual Report goes to participants within nine months of the plan year closing [30 September], or two months after the extension period ends if you extended [15 December].
No 5500 obligation means no SAR obligation.
If You Are Already Late
Penalties on a delinquent 5500 accrue per day, per filing, with no natural ceiling, which is what makes an old missed filing expensive rather than merely awkward.
The DOL runs a Delinquent Filer Voluntary Compliance Program for exactly this: file late voluntarily, before you are contacted, and the penalty is capped at a fraction of the exposure.
Six clocks, and they start without you.
COBRA failures are almost never a decision someone made. They are a day count that ran out.
Get the 2027 Michigan compliance calendar →
General Notice
Within 90 days of coverage beginning. Every COBRA deadline
Employer to Administrator
30 days after the qualifying event.
Administrator to the Individual
14 days after being notified, or 44 days from the event where you are your own administrator, which most employers are.
Election Period
At least 60 days, running from the later of the notice date or the date coverage would be lost.
Individual-Triggered Events
Divorce, a child aging off, a disability determination, the individual has 60 days to tell the plan.
Four things moved this year. Two of them can cost you.
Your Plan May Have Stopped Being Creditable
CMS revised the arithmetic behind Medicare Part D creditable coverage. The old simplified method asked whether the plan was expected to pay 60% of prescription drug costs. The revised one asks for 72% for 2026 and 73% for 2027. Nothing about your benefits has to change for the answer to flip.
For 2026 a group plan that does not claim the retiree drug subsidy may use either method. For 2027 only the revised method is available. Re-test before the October notice goes out. Sending a creditable notice for a plan that is not creditable hands an employee a Part D late enrollment penalty they had no way to see coming. How the Notice and CMS Disclosure Work
Wellness Rules Loosened, and in Your Favor
On 26 August 2026 Labor, HHS and Treasury issued new wellness guidance. If an employee meets a reasonable alternative standard partway through the plan year, you may start the reward from that point forward instead of backdating it to January.
The same guidance draws a line on disclosure. The alternative-standard notice belongs in every material that describes the program’s terms. It does not have to appear in one that merely mentions the program exists.
Parity enforcement is paused. Parity is not.
The Departments are not enforcing what was new in the 2024 mental health parity rule while they reconsider it through rulemaking. That relief reaches only the new provisions. The 2013 rule still stands.
What did not move: the 2021 statutory duty to produce a written comparative analysis of every non-quantitative treatment limitation, on request. Fully insured or self-funded, it is the plan’s document to hand over. Anyone describing parity as suspended is reading the headline rather than the statement.
HSAs Got Easier to Pair
Bronze and catastrophic-level plans became HSA-compatible on 1 January 2026 without having to meet the deductible test, direct primary care arrangements no longer block eligibility, and the telehealth-before-deductible safe harbor is permanent rather than a temporary extension.
If a plan design was ruled out of an HSA strategy at a prior renewal on any of those three grounds, the ruling is stale. It is worth re-pricing.
You May Not Have to Mail 1095-Cs Any More
The Paperwork Burden Reduction Act moved furnishing to an on-request model. Instead of mailing every employee a 1095-C, you can post a clear and conspicuous notice on your website saying a copy is available on request. For a quick estimate, use our free level-funded surplus refund calculator.
The conditions matter: the notice goes up by the furnishing deadline, stays up through 15 October, and a requested copy goes out within 30 days. Several states (California, New Jersey, Rhode Island, Massachusetts and DC among them) run their own furnishing mandates that this federal relief does not switch off. Not sure who counts as full-time for these forms? See the look-back measurement method.
Non-Discrimination Testing Is Less Settled Than It Looks
The timing everyone quotes for Section 125 testing comes from proposed regulations issued in 2007 that were never finalized. It is established practice rather than settled law. Check the dates and rules for your own group with our free employer size compliance checker.
What follows from that is practical, not academic: run a projection mid-year and the real test as of the last day of the plan year, because a Section 125 failure generally cannot be corrected once the year has closed.
Compliance is a service here, not a disclaimer.
We Track the Dates
Your account manager holds the compliance calendar for your plan year, so the reminder arrives before the deadline rather than after it.
We Prepare the Filings
ACA reporting, ERISA documents and the annual disclosures, prepared and reviewed, not handed back to you as a checklist.
We Bring in the Specialist
CPAs and ERISA attorneys are available through us when a question runs past what a licensed insurance broker should answer alone.
Rules move. So does your headcount.
When You Cross a Threshold
Fifty employees changes your obligations materially, and it is easy to cross without noticing. We watch the count rather than waiting for you to report it.
When You Cross a State Line
State leave, continuation and reporting rules do not follow your head office. With benefits expertise well beyond Michigan, a distributed workforce does not mean a second broker. For the rules Michigan adds on top of the federal ones, see Michigan benefits compliance.
Sourced from the agencies that write the rules: the U.S. Department of Labor for ERISA — Form 5500, the SAR, COBRA notices and participant disclosures; the Internal Revenue Service for the tax-code side — ACA employer reporting, the PCORI fee and non-discrimination testing; and CMS for Medicare Part D creditable coverage. General information, not legal or tax advice: which rules apply to your plan depends on its size, funding and documents. CFH Insurance Consultants are licensed insurance brokers; CPAs and ERISA attorneys are available through us.
The ten questions that come before the calendar.
Every one of these arrives from an employer who has read the dates and still cannot tell which of them are theirs.
How many employees do we need before these rules start applying?
There is no single number, which is why this trips people. COBRA starts at 20. The ACA employer mandate and FMLA both start at 50, count differently, and FMLA adds a second test — 50 employees within 75 miles of the worksite — before any one employee is eligible — and what bad FMLA administration costs is its own subject. The Form 5500 turns on 100 participants rather than employees. The Summary Plan Description applies from your first covered employee. An employer can sit below the mandate and still owe most of the list.
We are under 50. Does anything on the calendar apply to us?
Most of it. The Summary Plan Description, the Summary of Benefits and Coverage, the CHIP notice, the Part D notice and its CMS disclosure, and the gag clause attestation all apply without reference to the mandate threshold — and the Form 5500 arrives once you have 100 participants or a funded plan. What being under 50 spares you is the employer mandate itself and the 1094-C and 1095-C reporting that comes with it. The No Surprises Act protections apply to a plan of any size; see the No Surprises Act from the plan sponsor’s side.
What counts as affordable coverage this year?
For plan years beginning in 2026, an employee’s cost for the lowest-priced self-only option that meets minimum value cannot exceed 9.96 percent of income. For 2027 it rises to 10.22 percent. Income is measured through a safe harbor — W-2 Box 1, rate of pay, or the federal poverty line — because no employer knows an employee’s household income, which is what the statute nominally measures against. Cash paid to employees who waive coverage can count toward that cost too — see cash in lieu of benefits.
Do we still have to mail Forms 1095-C to employees?
Not necessarily. You may instead post a clear and conspicuous notice telling employees they can request one. The notice has to be up by March 2 and stay up through October 15, and a requested form has to be furnished within 30 days. Filing with the IRS is unchanged, and it has to be electronic once you file ten or more information returns of any kind in the year — W-2s and 1099s count toward the ten.
Does a small plan have to file a Form 5500?
Not if it had fewer than 100 participants at the beginning of the plan year and is unfunded, fully insured, or a combination of the two. Participants means covered employees plus people on COBRA and covered retirees — not dependents. And the exemption is from the filing only. It does nothing to the Summary Plan Description obligation, which is where most employers in this position are actually exposed.
Our plan is fully insured. Isn’t compliance the carrier’s job?
The carrier is responsible for the policy and for what it files on its own behalf. The plan sponsor owes the Summary Plan Description, the participant notices, the Form 5500 where one is due, and the answer when someone asks. The clearest case is the plan document itself: a certificate of coverage is not one, and neither is the benefits guide.
What is the gag clause attestation, and does a fully insured plan owe one?
It is an annual attestation, due December 31, that your plan’s contracts do not restrict access to cost and quality information. Both funding types owe it. If the issuer submits on a fully insured plan’s behalf, both the plan and the issuer are treated as having satisfied it — which is worth confirming each year rather than assuming.
How do we know our drug plan is still creditable for Part D?
Creditable means the coverage is expected to pay out at least as much as standard Part D. The determination comes from the carrier or an actuary, not from the employer, and it has moved for some plans as the Part D benefit itself has changed. Two deadlines hang off the answer: notice to Medicare-eligible employees before October 15, and the online disclosure to CMS within 60 days of the start of your plan year.
We missed a filing. What happens now?
For a late Form 5500 there is a voluntary correction program that costs materially less than waiting to be found — and it is only available before the Department of Labor contacts you. That is the entire argument for dealing with a missed filing the week you notice it rather than the quarter you notice it. Here is how a late filing gets corrected. If a letter has already arrived, here is what it means and what it costs.
An employee moved to another state. Does that change anything?
Compliance follows the work location, not the headquarters address. State continuation coverage, leave entitlements, pay rules and notice requirements attach where the employee actually works, and one remote hire can put you inside a state’s rules without anything on your plan changing.
General information about federal benefits compliance, not legal advice. Plan-specific questions belong with ERISA counsel, and we will bring them in.
Most compliance trouble starts with a word nobody defined or a rule nobody wrote down. Both are covered here.
More guides on this topic.
Medicare Secondary Payer Reporting
Who reports Medicare beneficiaries on your plan to CMS.
Benefits in a Merger or Acquisition: What to Decide Before and After Close
Keep every employee covered on day one, and harmonize the plans at the next renewal rather than in a rush.
Women’s Health and Cancer Rights Act for Employers
Plans that cover mastectomies must also cover reconstruction and related services under this federal law.
Newborns’ and Mothers’ Health Protection Act for Employers
This federal law sets minimum hospital stays for mothers and newborns in group health plans that cover maternity benefits.
Title VII of the Civil Rights Act for Employers
Title VII of the Civil Rights Act prohibits employment discrimination, and it applies to the benefits employers offer as well as to hiring and pay.
Small Welfare Plan Exemption
The DOL exempts welfare plans with fewer than 100 participants at the start of the plan year from the annual report when they are unfunded, insured or both.
How to Fix a Late ACA Filing
The order matters. Accurate forms filed quickly beat perfect forms filed after the next penalty tier begins.
IRS Letter 226-J: Employer Mandate Notice
Letter 226-J notifies an applicable large employer of potential liability for an employer shared responsibility payment.
Employer Mandate Penalty 4980H(b)
If coverage is offered but is unaffordable, fails minimum value, or is not offered to an employee who receives a premium tax credit, the 2026 payment is $5,010 for each such employee, capped at the 4980H(a) amount.
Employer Mandate Penalty 4980H(a)
If an employer does not offer coverage to at least 95% of its full-time employees and at least one of them receives a premium tax credit, the 2026 payment is $3,340 for each full-time employee after the first 30.
ACA Penalty: Intentional Disregard
When an employer intentionally disregards the filing or furnishing requirement, the penalty is $690 per return or statement for returns due in 2027, with no annual maximum.
ACA Penalty: After August 1 or Never Filed
The top tier applies to returns filed after August 1 and to returns never filed: $340 per return and $340 per statement, up to $680 per form.
ACA Penalty: Corrected by August 1
If the correct return is filed after the first 30 days but on or before August 1, the penalty is $130 per return and $130 per statement.
ACA Penalty: Corrected Within 30 Days
If you file a correct return or furnish a correct statement within 30 days of the deadline, the penalty is $60 per return and $60 per statement, under Sections 6721 and 6722.
Who Must File ACA Forms 1094-C and 1095-C
Applicable large employers, generally those that averaged at least 50 full-time employees including equivalents in the prior year, report offers of coverage every year.
ACA E-Filing Requirement: 10 or More Returns
Many small employers reach ten returns without a single 1095-C, because W-2s and 1099s count toward the total.
Forms 1094-C and 1095-C IRS Filing Deadline
Employers file Form 1094-C with the 1095-Cs on paper or electronically.
Form 1095-C Furnishing Deadline and Late Penalties
Employees’ Forms 1095-C are due by January 31. For 2025 reporting the IRS extended that date automatically to March 2, 2026 and says it will grant no additional extensions.
How Fast to Report Terminations to a Carrier
As soon as the date is firm. Each carrier sets its own deadline, and a late report costs more than a prompt one.
Does a Layoff Trigger COBRA?
Generally yes, if the employer is subject to COBRA and the layoff ends coverage.
Layoff Benefits Deadlines Calendar
A layoff starts several benefits deadlines at once. Here is the sequence, from separation date to year-end filings.
One Source of Records After a Layoff
Notices, terminations and billing should draw on the same records.
Right-Sizing the Group Health Plan
After a layoff, review plan design, contributions and funding for the group as it stands now, before the renewal.
Clean Termination Data After a Layoff
Payroll, enrollment and carrier records have to agree after a layoff.
Participation and Contributions After a Layoff
Carriers write participation and contribution minimums into the group contract.
ACA Counts and Reporting After a Layoff
ACA rules turn on counts of full-time employees. A reduction in force changes those counts, and the filings that depend on them.
Carrier Terminations After a Layoff
A layoff produces a list of names. Carriers need dates, coverage types and dependents tied to each one.
COBRA Notices After a Layoff
When a layoff ends health coverage, COBRA notices follow in a set order.
Equal Pay, Title VII and Religious Accommodation in Benefits
Federal anti-discrimination law treats benefits as part of compensation.
Michigan Jury Duty, Voting and Bereavement Leave for Employers
Employers manage a patchwork of leave rules beyond FMLA and sick time.
Terminating a Group Health Plan: COBRA, Filings and Notices
When an employer ends its group health plan, the last claims still have to be paid, participants still have to be told, and the final filings still have to be made.
Excess HSA Contributions and How to Correct Them
Excess contributions usually come from a job change, Medicare enrollment, or a family coverage change that nobody caught.
Contraceptive Coverage and Religious or Moral Exemptions
Most non-grandfathered group health plans must cover contraceptive services without cost sharing as preventive care.
Paid Family and Medical Leave Tax Credit (Section 45S)
Section 45S gives employers a credit of 12.5 to 25 percent of what they pay employees on qualifying family and medical leave, and since 2026 the credit is permanent.
Trump Account Employer Contributions (Section 128)
Section 128 lets an employer contribute up to $2,500 a year to an employee’s Trump Account or a dependent child’s, without the employee paying income tax on it.
Tuition Reimbursement Policy Design
The tax rule is short: up to $5,250 a year, tax-free, under a written plan.
Self-Insured Health Plan Nondiscrimination Rules
When a business pays for employee health benefits through a self-insured plan, the tax rules require that the plan not favor owners and highly paid employees.
Health FSA COBRA Rules: Employer Guide
A health FSA is a group health plan, so COBRA can apply to it.
McLaren Health Plan Group Health Insurance for Michigan Employers
McLaren Health Plan is a Michigan plan connected to McLaren Health Care and based in Flint.
Priority Health Group Health Insurance for Michigan Employers
Priority Health is a Michigan health plan based in Grand Rapids and part of Corewell Health.
Health FSA Debit Card Substantiation Rules
A benefits debit card is convenient, but every swipe still has to be shown to be a medical expense.
Annual and Lifetime Dollar Limits on Essential Health Benefits
Group health plans cannot put a lifetime or annual dollar limit on essential health benefits.
COBRA Second Qualifying Event: Extending to 36 Months
When a family already on COBRA has a second qualifying event, spouses and dependent children may be able to extend coverage to a total of 36 months.
Gift Cards, Cash and De Minimis Fringe Benefits
Employers often reward staff for wellness activity, tenure or performance with gift cards.
OTC Medicines and Menstrual Products in HSAs, FSAs and HRAs
Since the CARES Act, over-the-counter medicine and menstrual care products count as medical care for HSAs, health FSAs and HRAs.
Preexisting Condition Exclusions in Group Health Plans
Group health plans and insurers may not impose a preexisting condition exclusion.
Health FSA Uniform Coverage Rule for Employers
A health FSA must make the employee’s full annual election available from day one.
HIPAA Marketing and Psychotherapy Notes
Two areas where HIPAA is strict: using health information to market products, and handling psychotherapy notes.
HIPAA and State Law: When a State Rule Is Stricter
HIPAA sets a federal floor for privacy. State laws that conflict with it are generally preempted, but several exceptions favor stricter state rules.
HIPAA Permitted Uses: Treatment, Payment and Operations
HIPAA lets covered entities, including group health plans, use and share health information for core functions without asking each person first.
Lifetime and Annual Dollar Limits in Employer Health Plans
Group health plans cannot cap what they will pay for essential health benefits over a lifetime or in a year.
Medical Support Withholding and Payroll Limits
Medical child support orders can require payroll to withhold the employee share of premium.
Adoption Assistance Programs Under Section 137
An employer adoption assistance program can reimburse qualified adoption expenses on a tax-favored basis.
OCR HIPAA Complaints for Employer Health Plans
Anyone can file a HIPAA complaint with HHS Office for Civil Rights.
Provider Directory Accuracy for Employer Health Plans
Employees pick plans and doctors based on the provider directory.
Balance Billing Protections for Employer Health Plans
The No Surprises Act protects people in group health plans from many surprise bills.
HIPAA Enforcement and Penalty Tiers for Employer Health Plans
HIPAA penalties scale with how much the organization knew and whether it fixed the problem.
Summary Health Information and De-Identified Data in HIPAA
Employers ask carriers for reports to shop coverage or design the plan.
Family Members, Callers and Personal Representatives Under HIPAA
Benefits teams and carriers get calls from family members all the time.
Rescission of Coverage: When an Employer Plan Can Cancel Retroactively
A plan cannot simply cancel coverage back to its start date. Federal rules limit rescissions to fraud or intentional misrepresentation, and require advance written notice.
Grandfathered Health Plans: What the Status Means for Employers
A plan that existed on March 23, 2010 and has kept that status is exempt from some Affordable Care Act rules, though not most of them.
CHIP Premium Assistance Notice for Employers: Who Must Send It
Some states help low-income families pay for employer coverage through Medicaid or CHIP premium assistance.
Newborns’ Act and WHCRA
Two federal laws set minimum rules for specific benefits in a group health plan.
24/7 Nurse Lines by Carrier
Carriers name their nurse lines differently and publish different hours, numbers and eligibility.
Total Health Care 24/7 Nurse Line for Employees
Total Health Care is an HMO serving the greater Detroit area and surrounding counties for groups and individuals.
Humana 24-Hour Nurse Line for Employees
A Humana-branded flyer names it the HumanaFirst Nurse Advice Line and describes free, 24-hour health information and guidance.
McLaren Health Plan 24/7 Nurse Line for Employees
McLaren Health Plan describes a nurse case manager program that is free and voluntary, and a 24/7 nurse advice service for its Medicare members.
UnitedHealthcare 24/7 Nurse Line for Employees
UnitedHealthcare publishes a NurseLine that connects members with registered nurses 24 hours a day, seven days a week.
Cigna 24/7 Nurse Line for Employees
Cigna describes a Health Information Line staffed by nurses 24 hours a day, seven days a week, to help members understand symptoms and choose where to get care.
IRS Letter 226-J Explained
Letter 226-J is different from Letter 5699. It proposes an employer shared responsibility payment based on the returns you filed and your employees’ tax filings.
ACA Information Return Penalties: Sections 6721 and 6722
Two separate IRS penalties apply to ACA reporting. One is for failing to file correct returns on time and the other is for failing to give employees correct statements on time.
Humana Specialized Care Partners for Medicare Members
Humana lists outside organizations it has teamed up with to serve eligible Medicare members.
Humana Cancer Program: Nurse Coaching Explained
Humana says its Cancer Program offers telephone coaching from certified oncology registered nurses.
Humana Employer Group Medical Exit Explained
Humana says it is exiting its Employer Group Commercial Medical Products business.
McLaren Miracles Pregnancy Program
McLaren describes McLaren Miracles and a set of pregnancy resources, and some items on the page are labeled as Medicaid benefits.
McLaren Depression Program: Eyes Wide Open
McLaren describes Eyes Wide Open as a program for members with depression.
McLaren Chronic Kidney Disease Management
McLaren describes a comprehensive program for members with chronic kidney disease that works with the member and their doctors on the treatment plan.
McLaren Asthma Disease Management Program
McLaren describes a comprehensive asthma program that starts with early identification of the member and relies on education, monitoring and coordination with the primary care physician.
Cigna Employee Assistance Program Explained
Cigna describes its Employee Assistance Program as confidential support for mental health, behavioral conditions and substance use, plus legal, financial and work-life services.
Cigna Lifestyle Management Coaching Explained
Cigna describes Lifestyle Management as goal-based coaching for weight, tobacco cessation and stress management.
Cigna Personal Health Advocates Explained
Cigna lists Personal Health Advocates among its employer wellness offerings.
Omada for Cigna Healthcare Prediabetes Program
Cigna describes Omada as a digital behavioral counseling program for customers with prediabetes or at risk for diabetes.
Aetna Community Care Program Explained
Aetna describes Community Care as goal-based health management with flexible support and coaching for chronic conditions.
Aetna Behavioral Health Support Explained
Aetna describes behavioral health programs for employers that include counseling, case management and digital tools.
Aetna Online Condition Programs Explained
Aetna describes online disease management programs that members can take to boost their nurse coaching sessions.
HAP Palliative Care and Hospital at Home
HAP lists two home-based services: palliative care for serious illness and Hospital at Home as an alternative to a hospital stay.
HAP Digital Musculoskeletal Program Explained
HAP describes a virtual platform run by Protera Health for muscle and joint care.
HAP Care Management Program Explained
HAP describes its care management program as a collaborative process of assessment, planning and care coordination.
Priority Health Kidney and Diabetes Care Support
Priority Health describes this as support from its care management team for members managing chronic kidney disease, diabetes and hypertension.
Priority Health Kivo Virtual Pulmonary Rehab
Priority Health describes Kivo as a nine week virtual COPD recovery program done at home.
Priority Health Livongo for Type 2 Diabetes
Priority Health describes Livongo, now owned by Teladoc Health, as a digital type 2 diabetes program available through an employer group buy-up.
BCBSM Behavioral Health Solutions for Employers
The carrier says behavioral health is embedded for fully insured and self-insured customers and their members, though it may not apply where behavioral health is carved out.
BCBSM Kidney Care with Strive Health
This program is described in a provider facing home based services document, not on an employer page.
BCBSM Blue Cross Coordinated Care Explained
Blue Cross Coordinated Care is described by the carrier as one-on-one, personalized support for members with chronic or complex conditions.
BCBSM Diabetes and Diabetes Prevention Programs
Blue Cross Blue Shield of Michigan lists diabetes management and diabetes prevention as two programs on its employer condition management page.
UnitedHealthcare COPD and Asthma Programs
UnitedHealthcare describes two separate respiratory programs, one for COPD and one for asthma.
UnitedHealthcare Maternity and Fertility Programs
These programs add guidance, nurses and virtual support around pregnancy and family building.
UnitedHealthcare Real Appeal for Employers
Real Appeal pairs a health coach with online sessions and a home kit.
UnitedHealthcare Rewards for Employers Explained
UnitedHealthcare Rewards is an incentive program inside the UnitedHealthcare app.
Priority Health Muscle, Joint and Pain Care
Priority Health lists virtual physical therapy, a surgical Centers of Excellence rider, a virtual pain clinic and a supplemental product that rewards use of top-rated providers.
Priority Health Diabetes and Weight Programs
Priority Health lists Virta, Livongo, Omada and the National Diabetes Prevention Program for commercial group members.
Priority Health PriorityWell Platform Explained
PriorityWell is the digital health and wellness solution Priority Health launched in 2022 for large-group employers.
McLaren Condition and Complex Care Management
McLaren Health Plan publishes member information on adult and child complex care management, asthma and diabetes, and says Health Advantage includes disease management.
Is Humana Go365 Still Available to Employers?
Humana’s Go365 workplace page is still live, but Humana announced in 2023 that it was leaving employer group commercial medical.
Humana Go365 Whole-Person Resources
Humana says Go365 goes beyond traditional workplace wellness by offering resources for everyday stressors.
HAP Condition and Care Management Programs
HAP lists several clinical programs for members with chronic or complex conditions.
HAP Weight, Tobacco and Behavioral Health
HAP lists nutritional counseling and weight-loss coverage, a tobacco quit line with phone coaching and a behavioral health team.
HAP Reward Your Health Incentive Program
HAP describes Reward Your Health as its next generation of employee well-being, with incentives for health behavior changes and biometric improvements.
Cigna Pathwell Bone and Joint Program
Pathwell Bone and Joint is a condition-specific care program, not a wellness app.
Cigna MotivateMe Incentive Program Explained
Cigna lists MotivateMe as an incentive program for employers.
Cigna Health Matters Program for Employers
Cigna Health Matters is the assessment and engagement layer that sits on myCigna.
Well-Being Plus and Custom Well-Being
Blue Cross says self-funded customers can enhance the included Well-Being program through Well-Being Plus or Custom Well-Being reward programs.
Blue Cross Well-Being for Employers
Blue Cross says its Well-Being Base program is built into every BCBSM and Blue Care Network medical plan, fully insured and self-funded alike.
Aetna Maternity Support and Maven Option
Aetna describes maternity support as a mix of nurse outreach, education and virtual resources.
Aetna Women’s Health and Fertility Benefits
Aetna’s women’s health page describes family planning and fertility support as flexible plan designs.
Aetna Well-Being Reported Results Explained
Aetna publishes outcome figures for Health Your Way from its 2025 book of business.
Aetna Health Your Way Well-Being Platform
Aetna describes Health Your Way as a single hub for whole-health coaching, tailored recommendations and connected digital tools.
Employer Student Loan Repayment and Tuition Reimbursement: the Section 127 Rules
Employer-paid tuition and employer-paid student loans are the same benefit under the tax code.
Compliance Services With Hold-Harmless Protection
What written protection on COBRA and ERISA services covers, and what to ask any vendor.
Compliance Service Bundles for Employers
Related compliance services arranged together under one arrangement.
ERISA Claims and Appeals
What employers must have in place.
ERISA Fidelity Bond
Who needs one and who does not.
Employee Eligibility Classes in Group Health Plans
How to define classes and avoid health-factor discrimination.
Benefits Compliance in Bloomfield Hills Without the Guesswork
Most employers are not sure which benefits rules apply to them. The deadlines are scattered through the year. The notices have strange names. Benefits compliance in Bloomfield Hills gets simpler when someone puts it all on one calendar for you.
We are CFH Insurance Consultants, an independent benefits firm on Woodward Avenue since 2007. No carrier owns us. We help employers in Oakland County, Detroit and across Michigan stay on top of the rules.
Benefits Compliance
Benefits compliance means following the laws that govern your employee benefits. The main one is ERISA. ERISA is the federal law that sets rules for most employer health plans, including the documents and notices you must give employees.
Here is how we help with benefits compliance in Bloomfield Hills:
- We help keep you ERISA compliant.
- We build a yearly calendar of your filings and notices.
- We check that your plan documents and notices are in place.
- We point out which rules apply at your size.
- When a question needs a legal or tax answer, clients get access to ERISA attorneys and CPAs through the firm.
What benefits laws apply to Michigan employers?
It depends mostly on your size. Here are key thresholds and dates:
- ACA employer mandate: applies at 50 or more full-time-equivalent employees. Those employers send Forms 1095-C early each year.
- COBRA: federal COBRA applies at 20 or more employees.
- FMLA: applies at 50 or more employees within 75 miles.
- Medicare Part D notice: the creditable coverage notice goes out by October 15.
- Form 5500 and PCORI fee: due by July 31 for calendar-year plans that must file.
- Group term life: employer-paid coverage above $50,000 is taxable to the employee.
- Michigan Earned Sick Time Act: in effect since February 2025.
Do small employers have to offer COBRA in Michigan?
Only at 20 or more employees. Michigan has no state mini-COBRA law. So federal COBRA applies at 20 or more employees. Under 20, the employer has no statutory continuation duty, although some insured contracts let a departing employee convert to an individual policy.
That surprises many small employers who expect a state rule like other states have. If you are near 20 employees, check your headcount each year so you know when COBRA starts to apply.
Common questions
Do we have to file a Form 5500?
Some plans must and some do not. It depends on your plan size and setup. We help you find out and put the date on your calendar. The usual test: under 100 participants at the start of the plan year and fully insured or paid from general assets means no filing. A plan with a trust files at any size.
What is the Medicare Part D notice?
It tells employees on Medicare whether your drug coverage is at least as good as Medicare’s. It is due by October 15. It goes to Medicare-eligible employees and dependents, not only retirees, and is also due when someone first becomes eligible and on request. A separate disclosure goes to CMS within 60 days after your plan year begins.
Does the Earned Sick Time Act affect our benefits?
It affects your paid time off policies. We can help you connect those questions to the right advisor. Paid sick time sits outside the health plan, but it touches benefits where leave runs alongside short-term disability or an eligibility rule based on hours worked. We check that your disability plan and leave policy work together.
Talk to us about benefits compliance in Bloomfield Hills
Book a 30-minute call or send us your renewal, and we will map out your compliance calendar. Visit us at 41000 Woodward Avenue, Suite 350 East, Bloomfield Hills, MI 48304, or call 248.370.8853.
Send Us Your Renewal Book a 30-Minute Call
Send us your renewal.
We’ll tell you whether it looks competitive, where we see opportunity, and the five questions we’d put to your carrier. No cost, and no obligation to move anything.
The renewal letter
Your current plan summary
Contribution split by tier
Enrolled counts by tier
Four documents, two more if your group is 50 or more. Nothing else; every extra one is a reason to postpone.
An independent employee benefits consulting firm. We look at the entire benefits program — cost, plan performance, risk and administration.
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