End-of-Year Compliance: A Checklist
Your End-of-Year Benefits Compliance Action Plan
As 2026 winds down, HR and benefits administrators face compliance deadlines that can't be missed. Finishing these tasks now helps protect your business from penalties and audit exposure and keeps employees clear on their coverage. Here's what's on the calendar.
October:
Creditable Coverage Notices must go out before October 15. They go to every Medicare-eligible individual who is eligible for your plan's prescription drug coverage, including active employees, COBRA beneficiaries, and covered spouses and dependents. When in doubt, send the notice. If you filed a Form 5500 extension, that deadline is also October 15, and missing it can bring significant Department of Labor penalties. October is also a good time to audit your COBRA notices for timeliness and accuracy. You can then calculate your 2027 COBRA rates (up to 102 percent of plan cost) to share with participants.
November–December:
Update COBRA premiums in your billing system and send any open enrollment reminders . Make sure your Section 125 plan documents reflect this year's changes, and run nondiscrimination testing for your FSAs and cafeteria plan. Confirm how you'll handle unused FSA balances , whether through carryover, a grace period, or a runout period, and tell employees so they can plan ahead. Finalize your ERISA plan-year closeout documentation , and update your Summary Plan Description if your plan changed. Then review your employee handbook for new state and local requirements.
Before Year-End:
If you're an Applicable Large Employer, start gathering data for your 2026 ACA reporting . Forms 1095-C are due to employees by March 2, 2027, and electronic filing with the IRS is due March 31, 2027. Confirm that you've tracked full-time status accurately for each month. Also check that your lowest-cost self-only plan meets the 2026 affordability threshold of 9.96 percent.
Don't forget your annual creditable coverage disclosure to CMS . It's due within 60 days after the start of your plan year and within 30 days of any change in status.
Tackle one section at a time, and reach out to us if you need guidance on the requirements specific to your business.
Seasonal Employees and Health Insurance
Seasonal and part-time employees can give your business much-needed flexibility during busy periods, but they can also raise important health insurance questions.
Before hiring, review your group health plan’s eligibility requirements, including rules for hours worked, employee classifications, and waiting periods. Make sure seasonal employees understand whether they qualify for coverage and, if so, when coverage begins and ends.
Don’t Overlook ACA Employee Counts
Health plan eligibility and Affordable Care Act (ACA) employer requirements aren’t necessarily the same thing. Under ACA employer shared responsibility rules, an employee generally is considered full-time when averaging at least 30 hours of service per week or 130 hours per month. Part-time employees also matter. Their hours are combined when determining full-time equivalent employees (FTEs), which can affect whether your business is considered an Applicable Large Employer (ALE). An employer generally becomes an ALE when it averages at least 50 full-time employees, including FTEs, during the previous calendar year. If your business becomes an ALE, you may have additional ACA responsibilities, including offering qualifying, affordable health coverage to full-time employees and their dependents, and meeting annual IRS reporting requirements.
Special rules may apply when seasonal workers temporarily push your workforce above that threshold, so don’t assume every temporary hire is treated the same.
Need help? Contact our agency to review your group benefits and discuss how seasonal or part-time hiring may affect your health plan and ACA responsibilities.
OEP is Coming: What's Important to Know
The ACA Marketplace Open Enrollment Period (OEP) is just around the corner. In most states Open Enrollment for 2027 coverage runs from November 1 through January 15 , giving individuals and families an opportunity to enroll in coverage, renew an existing plan or choose a different option for the year ahead. Enrollment deadlines can vary by state, so contact our agency to confirm the exact dates that apply to you.
Now is a good time to start getting prepared. Think about what may be different for your household in 2027, including expected income, household size, health care needs, prescriptions, and preferred doctors or other health care providers. If you already have Marketplace coverage, watch for notices from both the Marketplace and your insurance company regarding your 2027 coverage. Keep those notices handy—they can contain important information about your current plan, changes for the new year, and steps you may need to take.
Even if you’re happy with your current coverage, it’s worth reviewing your options once 2027 plans are available. Plans, premiums and benefits can change from year to year, and your own needs may have changed as well. When comparing plans, look beyond the monthly premium and consider deductibles and other out-of-pocket costs, whether your doctors and other providers participate in the plan’s network, and whether your prescriptions and preferred pharmacies are covered. If you receive financial assistance through the Marketplace, start thinking now about your 2027 income estimates and household information so the Marketplace can determine the savings for which you may qualify.
Get a head start on Open Enrollment. Contact our agency to schedule an appointment for November 1 or later to review your 2027 Marketplace coverage options. When Open Enrollment begins, we can help you compare available plans, review costs and coverage, and consider which option may fit your needs and budget.
