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As we continue to make our way through the calendar year, so do the compliance requirements. A few compliance reminders as we head into a busy month ahead.
Compliance Reminders
March 1: CMS Disclosure for Creditable Prescription Drug Coverage
Group health plans that provide prescription drug coverage to Medicare Part D-eligible individuals must complete the annual Creditable Coverage Disclosure to the Centers for Medicare & Medicaid Services (CMS). This filing confirms whether the plan’s prescription drug coverage is considered creditable or noncreditable for the prior calendar year.
For additional information regarding the CMS Creditable Coverage Disclosure, click here.
March 2: ACA Sections 6055 and 6056 Reporting (Manual Filers Only)
Employers filing ACA Forms 1094/1095 manually must submit their filings by March 2, 2026. Manual filing is permitted only for employers submitting fewer than 10 returns. All other employers are required to file electronically, with an extended deadline of March 31, 2026.
March 2: Form 1095B / 1095C Distribution Requirements
Applicable Large Employers (ALEs) must either:
- Post a clear, conspicuous, and reasonably accessible notice on their website by March 2, 2026, informing employees that their Form 1095B or 1095C is available upon request. The notice must remain posted through October 15, 2026, and requested forms must generally be provided within 30 days of the request; or
- Automatically furnish Forms 1095B or 1095C to employees by March 2, 2026, in lieu of using the notice and request method.
March 31: Forms 1094/1095 Filed with IRS
ALEs must file with the IRS the Forms 1095-C provided to employees along with a 1094-C transmittal form. Non-ALEs that sponsor a self-insured health plan must file with the IRS the Forms 1095-B provided to covered individuals along with a 1094-B transmittal form. The forms must be filed electronically.
Current National Headlines in the News
With HR and employee benefits topics regularly in the news, staying current on what’s really important can often be challenging. For the most current listing of those articles, see the February 17 Weekly Digest (also attached below).
Another widely discussed issue in recent news is the Trump Rx initiative. What exactly is it? Read about it here.
Upcoming Compliance Reminders
Although June may feel far away, it will be here before we know it — and carriers will soon begin preparing for the annual Prescription Drug Data Collection (RxDC) filing. Because the filing deadline is June 1, the data gathering process starts well in advance.
Most medical carriers will require employers to complete a brief data form so they can finalize the RxDC submission on your behalf. These forms typically request plan-specific details needed for accurate reporting.
To ensure timely submission, please complete and return any required carrier forms as soon as you receive them. Carriers cannot finalize the filing without your organization’s direct response. This Acrisure Benefits Bulletin explains a lot. If you have any questions about the RxDC filing process or are unsure what steps to take, please reach out to your Account Management Team.
Compliance Disclaimer:
This communication is for informational purposes only and should not be considered legal or tax advice. Employers should consult with legal counsel or other appropriate professionals regarding their specific compliance obligations.