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Introduction

Each year, employers sponsoring group health plans face a range of federal reporting obligations tied to employee benefits. These requirements span multiple agencies and cover everything from tax reporting to healthcare transparency and plan compliance. With evolving rules and new administrative options, staying organized and informed is essential.

For many employers and HR teams, the challenge is not just understanding each requirement, but also knowing when they apply, who is responsible, and how they fit into the broader compliance calendar. Missing a deadline or misunderstanding a requirement can create unnecessary risk or administrative burden.

This article provides a structured overview of the primary federal reporting requirements for 2025. It highlights key deadlines, clarifies employer responsibilities, and outlines where coordination with carriers, TPAs, or advisors is typically required.

Key Takeaways

• Most federal reporting requirements follow a predictable annual calendar, with key deadlines from January through December.
• Responsibility for reporting often depends on plan type (fully insured vs. self-funded) and employer size.
• ACA reporting deadlines remain March 3 (employee statements) and March 31 (IRS filing), with new flexibility for distributing forms.
• Many newer requirements, such as RxDC reporting and gag clause attestations, rely heavily on vendor coordination.
• Some obligations, like mental health parity analysis, are not filed annually but must be maintained and available upon request.

Understanding the Annual Compliance Timeline

While requirements vary, most employers can map their obligations across a standard calendar year:

• January 31: Form W-2 reporting (including cost of coverage, if applicable)
• March 1: Creditable coverage reporting to CMS (calendar year plans)
• March 3: Deadline to furnish Forms 1095 to employees
• March 31: Deadline to file ACA reporting with the IRS (electronic)
• June 1: Prescription drug (RxDC) reporting due
• July 31: PCORI fees and Form 5500 filings (calendar year plans)
• December 31: Gag clause attestation deadline

Some deadlines vary for non-calendar year plans, particularly Form 5500 filings and creditable coverage reporting.

Form W-2 Reporting: Cost of Coverage

Who Must Report?

Employers that filed 250 or more Forms W-2 in the prior year must report the cost of employer-sponsored health coverage.

What Is Included?

• Total cost of coverage (employer + employee contributions)
• Applies to group health plans only
• Excludes:
  • Health Savings Accounts (HSAs)
  • Standalone dental or vision plans
  • Most wellness adjustments

Key Considerations

• Reported in Box 12 (Code DD) of the W-2
• For informational purposes only; does not affect taxable income
• Based on the coverage tier elected (e.g., employee-only vs. family)

Creditable Coverage Reporting to CMS

What Is Creditable Coverage?

Prescription drug coverage is considered “creditable” if it is at least as valuable as Medicare Part D coverage.

Why It Matters

• Impacts employees’ ability to delay Medicare Part D enrollment without penalties
• Late enrollment penalties can increase monthly premiums

Employer Responsibilities

• Determine whether coverage is creditable
• Distribute annual notices to employees
• Submit online disclosure to CMS:
  • Within 60 days of plan year start
  • Within 30 days of plan termination or status change

Clarification

There is no employer penalty for offering non-creditable coverage, but reporting is still required.

ACA Employer Reporting (Forms 1094/1095)

Who Must File?

• Applicable Large Employers (ALEs): 50+ full-time equivalents
• Any employer with a self-funded or level-funded plan

What Must Be Reported?

• Offers of coverage (for ALEs)
• Enrollment information (for self-funded plans)
• Includes employees, dependents, COBRA participants, and retirees

2025 Deadlines

• March 3: Provide forms to individuals
• March 31: File electronically with the IRS

What’s New?

Recent legislative updates include:

• Alternative distribution method:
  Employers may post a notice of availability instead of sending forms automatically
• Simplified electronic consent rules
• Expanded response time (minimum 90 days) for IRS penalty letters
• 6-year statute of limitations for enforcement

Practical Note

Even with the notice option, employers must provide forms upon request.

Prescription Drug Reporting (RxDC)

Overview

This reporting requirement supports healthcare transparency efforts by collecting data on medical and prescription drug spending.

Who Handles It?

• Typically completed by:
  • Insurance carriers
  • Third-party administrators (TPAs)
  • Pharmacy benefit managers (PBMs)

Employer Role

• Confirm vendors are submitting required data
• Provide:
  • Employer vs. employee premium contributions
  • Basic plan details

Key Insight

Most reporting is submitted on an aggregate basis, meaning employers may not receive plan-specific data.

Form 5500 Filing Requirements

When Is Filing Required?

• Plans with 100+ participants at the start of the plan year
• Funded plans (regardless of size)

What Counts as a Participant?

• Employees (active and former)
• COBRA participants
• Does not include dependents

Filing Details

• Due 7 months after plan year end (July 31 for calendar year plans)
• 2.5-month extension available via Form 5558

Efficiency Tip

Using a wrap document can consolidate multiple plans into a single filing.

PCORI Fees

What Are They?

Fees that fund the Patient-Centered Outcomes Research Institute.

Who Pays?

• Fully insured plans: paid by carriers
• Self-funded plans: paid by employers

Key Details

• Approx. $3 per covered life
• Due July 31 annually
• Reported using Form 720 (Q2 filing)

Important Note

Short plan years may result in multiple fees due in the same year.

Gag Clause Attestation

What Is Required?

Employers must confirm that their contracts do not restrict access to plan data.

Key Considerations

• Applies to agreements with:
  • Carriers
  • TPAs
  • PBMs
• Includes downstream vendor contracts

Who Completes It?

• Fully insured: often handled by carriers
• Self-funded: typically employer responsibility, supported by vendors

Deadline

• Must be completed annually by December 31

Mental Health Parity: Comparative Analysis Requirement

What Is Required?

Plans must demonstrate that mental health and substance use disorder benefits are comparable to medical/surgical benefits.

What Must Be Documented?

A written comparative analysis of:

• Financial requirements (e.g., deductibles, copays)
• Treatment limitations (e.g., visit limits)
• Non-quantitative limitations (e.g., prior authorization, medical necessity)

Employer Responsibilities

• Ensure analysis is completed
• Maintain documentation
• Provide upon request (not filed proactively)

New for 2025

A plan fiduciary must certify that:

• A qualified vendor was selected
• The analysis was reviewed
• Any gaps are being addressed

Clarifications & Added Context

• Fully insured vs. self-funded matters: Many reporting obligations shift from employer to vendor depending on plan structure.
• No “one-size-fits-all” approach: Employers often share responsibility with multiple vendors and must coordinate accordingly.
• Documentation is critical: Even when filings are not required, maintaining records is essential for audits or participant requests.

Disclaimer

This content is provided for general informational purposes only and is not intended as insurance advice. Coverage, terms, and availability can vary by carrier and state. For guidance specific to your situation, we recommend speaking with a licensed insurance professional.

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