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2024 Year-End Tasks for Employee Benefits Plans

By December 2, 2024December 5th, 2024No Comments

As 2024 comes to a close, employers must navigate a range of compliance requirements for their employee benefit plans. Despite the hectic nature of the season, ensuring these tasks are completed will help avoid penalties and start 2025 on the right foot.

If your plan runs on a calendar year (effective 1/1), here’s a comprehensive checklist of benefits-related tasks to tackle before the end of the year:

Critical Year-End Compliance Tasks

  1. Submit Gag Clause Attestation
    Employers must confirm that gag clause attestations for their health plans have been submitted. If an insurer or third-party administrator (TPA) handles your attestation, confirm their submission to meet federal requirements.

  2. Amend Plan Documents
    Update plan documents to reflect any discretionary changes made during 2024. Ensure that amendments align with both your organization’s goals and legal standards.

  3. Distribute Annual Notices
    Confirm that required annual notices have been provided to employees. These may include:

    • Children’s Health Insurance Program (CHIP) notice

      • Women’s Health and Cancer Rights Act (WHCRA) notice

      • Medicare Part D Creditable Coverage notice

      • Notice of Special Enrollment Rights

  4. Perform Nondiscrimination
    Testing
For flexible spending accounts (FSAs), health reimbursement arrangements (HRAs), and self-funded health plans. Complete nondiscrimination testing to confirm compliance and prevent favoring highly compensated employees.

  5. Remind Employees About FSA and HRA Rules
    Notify employees of the deadlines for using any remaining funds in their FSAs or HRAs. If your plan offers a grace period or rollover option, clearly communicate these details.

Prepare for 2025

  1. Ensure Affordable Health Coverage
    Applicable large employers (ALEs) must ensure health plan coverage meets affordability requirements for full-time employees under the Affordable Care Act (ACA).

  2. Update Plan Limits for 2025
    Review and update contribution and benefit limits for the upcoming year, such as:

    • Health savings account (HSA) contribution limits

      • FSA maximum contributions

      • Retirement plan deferral limits

  3. Revise Employee Communications
    Update summary plan descriptions (SPDs) and other materials to reflect any benefit changes for 2025. Ensure communications are clear, concise, and distributed promptly.

  4. Prepare for IRS Reporting Deadlines
    ALEs should finalize preparations for Forms 1094-C and 1095-C to report 2024 health coverage. Key deadlines include:

    • January 31, 2025: Distribute Form 1095-C to employees

      • March 4, 2025: E-file forms with the IRS

By staying proactive, employers can ensure compliance, streamline transitions, and build a strong foundation for employee benefit plans in 2025. For personalized guidance or support, reach out to McConkey Insurance & Benefits—we’re here to help.

Brian Orsinger

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