2022 HR Compliance Calendar | Nonprofit HR

FSA and HRA Nondiscrimination Testing

Timeframe: Always 7 months after the end of a plan year.

Relevant Links/Notes: Connect with your FSA and HRA vendor to learn more about the testing.

Planning for Benefit Open Enrollment

Timeframe: At least one month before renewal, ideally two months if possible.

Open Enrollment Benefits Guide

FTE Calculation

Timeframe: Must be completed annually (usually prior or after open enrollment).

ACA Information for Employers: Counting Full-time and Full-time Equivalent Employees

Update salaries annually for life insurance, STD, LTD

Timeframe: Do this whenever salaries are updated, usually once a year and recommend setting a calendar reminder.

Relevant Links/Notes: Life insurance carriers use each employees salaries to determine their life insurance premiums; usually carriers will only allows for updates to be within 30 days of the effective date of the change.

COBRA Notifications

Timeframe: For employers with 20 or more employees in the previous calendar year. Be sure to also check if there are any state COBRA laws that change the threshold to less than 20 employees. For Federal compliance, within 14 days of term notification must go out, in writing. Employees have up to 60 days of term to enroll. Depending on situation Employees may be able to access COBRA for 18 months or up to 24 months.

Relevant Links/Notes: It is affordable and good compliance coverage to consider having a Third Party Administrator (TPA) in place to manage this.

COBRA Notifications

Form 5500

Timeframe: July 31st – Deadline to file Form 5500 (Retirement plan), annual return/report of employee benefit plan, unless applying for extension to 10/15/20.

Instructions for completing Form 5500

Form 8955-SSA

Timeframe: July 31st – Deadline to file Form 8955-SSA, annual statement identifying participants with deferred vested benefits.

Information about Form 8955 SSA

Retirement Plan Universal Availability Notice to all staff

Timeframe: Annually – All employers with a retirement plan.

Relevant Links/Notes: Under this rule, if any employee of the employer maintaining the 403(b) may participate, then all of the employer’s employees must be given the opportunity to participate

Issue Snapshot – 403(b) Universal Availability Requirement

Medicare Part D Notifications

Timeframe: October 15 of every year; 1 or more employees (requires employers that offer a prescription drug coverage).

Relevant Links/Notes: Employer is only required to send to all Medicare-eligible participants (including COBRA participants and eligible dependents), but usually just sends to all participants. This notification indicates whether the plan’s prescription drug coverage is creditable or non-creditable with Medicare prescription drug coverage.

Creditable Coverage Disclosure Form

What is creditable coverage?

Retirement Plan Distribution of Summary Annual Report (after submission of 5500)

Timeframe: The Retirement plan Summary Annual Report (SAR) must be provided within nine months from the close of the plan year (no later than September 30 for calendar year plans); plus a two-month extension if an extension was filed. The SAR should be distributed to all participants of the plan during the year for which the plan information is being reported.

Summary Annual Report

Safe Harbor Notice to all staff (Retirement plan) – generated by the vendor – needs to be passed on to employees via mail or email

Timeframe: The notice must be provided to eligible employees between 30 to 90 days prior to the start of the plan year.

Relevant Links/Notes: ERISA Requirements for meeting guidelines for electronic delivery of retirement plan notices

PCORI Fees (for HRAs & self-funded medical plans)

Timeframe: Payment is due by July 31 following the end of the calendar year in which the plan year ended; The Form 720 and fees are due on July 31 of the calendar year following the last day of the plan year. For example, if your medical plan year ended in 2021, your Form 720 is due by July 31, 2022.

Relevant Links/Notes: Under the ACA, the Patient-Centered Outcomes Research Institute (PCORI) emerged to support clinical effectiveness research. PCORI is funded by fees paid by certain health insurers and sponsors of self-insured health plans. Its purpose is to fund research that can help patients and those who care for them make better-informed decisions about the health care choices they face every day.


Patient-Centered Outreach Research Institute Filing Due Dates and Applicable Rates

DC Paid Family Leave Notification

Timeframe: At least once a year

Relevant Links/Notes: Information on Paid Family Leave in the District of Columbia

Mid-Year FSA Non-Discrimination Testing

Timeframe: In the middle of the plan year

Relevant Links/Notes: It is recommended that employers do one test mid-plan year in order to determine whether additional steps must be taken before the end of the plan year so that the plan passes the nondiscrimination tests by the end of the plan year.

Deadline to furnish Forms 1094-C or 1095-C to employees

Timeframe: Tuesday, March 2, 2021

Relevant Links/Notes: Employers with 50 or more full-time employees (including full-time equivalent employees) in the previous year use Forms 1094-C and 1095-C to report the information required under sections 6055 and 6056 about offers of health coverage and enrollment in health coverage for their employees. Form 1094-C must be used to report to the IRS summary information for each Applicable Large Employer (ALE) Member and to transmit Forms 1095-C to the IRS. Form 1095-C is used to report information about each employee to the IRS and to the employee. Forms 1094-C and 1095-C are used in determining whether an ALE Member owes a payment under the employer shared responsibility provisions under section 4980H. Form 1095-C is also used in determining the eligibility of employees for the premium tax credit.

Affordable Care Act Tax Provisions for Employers

Deadline to disclose annual funding notice to retirement plan participants, beneficiaries, labor organizations (if applicable), and PBGC (if more than $50 million underfunded) – plans with 100 or fewer participants may have additional time to furnish

Timeframe: Friday, April 30, 2021

Relevant Links/Notes: All employers with retirement plan.

Retirement Topics – Notices

Deadline to disclose summary of material modifications to retirement plan participants and beneficiaries

Timeframe: Thursday, July 29, 2021

Relevant Links/Notes: All employers with retirement plan, if there were any changes made to the Summary Plan Description

Summary of Material Modifications

Deadline to file Form 5500 or the extension. The deadline may fall 7 months from the end of the plan’s calendar year, and often end of July for those plans operating on regular calendar year

Timeframe: Monday, August 2, 2021

Relevant Links/Notes: All employers with retirement plan

IRS Form 5500 Corner 

Deadline to disclose Summary Annual Report to retirement plan participants and beneficiaries (or two months after Form 5500 is due, if extension was provided)

Timeframe: Thursday, September 30, 2021

Relevant Links/Notes: All employers with retirement plan

What Is a SAR, and When Must It Be Provided?

Enrollment begins for 2020 health insurance plans for individuals through the Marketplace

Timeframe: Monday, November 1, 2021

Relevant Links/Notes: 1-50 employees

Official Marketplace Dates and Deadlines | HealthCare.gov

Overview of SHOP: Health insurance for small businesses

Deadline to disclose Summary Annual Report to retirement plan participants and beneficiaries if extension was provided

Timeframe: Wednesday, December 15, 2021

Relevant Links/Notes: All employers with retirement plan

What Is a SAR, and When Must It Be Provided?