- On March 25, 2026
As the year moves forward, employers sponsoring group health plans should review upcoming midyear compliance responsibilities. Various federal laws—including ERISA, COBRA, and the No Surprises Act—require certain reports and participant disclosures during the spring and summer. Staying on top of these obligations helps avoid penalties and ensures employees receive required information on time.
Summary Plan Description – Newly Covered Participants
Group health plans subject to ERISA must furnish a Summary Plan Description to new participants within 90 days after their coverage begins. For plans operating on a calendar year, employees who enrolled effective January 1 must receive their SPD by April 1. The SPD must also incorporate required federal notices, where applicable (for example, the Newborns’ and Mothers’ Health Protection Act Notice).
Deadline: April 1, 2026 (January 1 Plan Years)
COBRA General Notice – Newly Covered Participants
Plans subject to COBRA must provide a general notice explaining COBRA rights to covered employees—and covered spouses, if applicable—within 90 days after coverage starts. For calendar-year plans, this typically aligns with an April 1 deadline.
Deadline: April 1, 2026 (January 1 Plan Years)
Prescription Drug Data Collection (RxDC) Reporting
Group health plans and insurers are required to annually report prescription drug and healthcare spending data to the Centers for Medicare & Medicaid Services (CMS). This is commonly referred to as RxDC reporting. Employers often rely on carriers, third-party administrators, or pharmacy benefit managers to complete and submit this reporting.
Deadline: June 1, 2026
Form 5500 Filing
Employers must file an annual return/report (Form 5500) with the Department of Labor for ERISA-covered group health plans. Certain welfare plans are exempt if they are fully insured, unfunded, or a combination of both, and have fewer than 100 participants.
For calendar-year plans, the standard filing deadline is July 31. A one-time extension of 2.5 months is available by submitting IRS Form 5558 by the original due date.
Deadline: July 31, 2026 (January 1 Plan Years)
PCORI Fees (Self-Insured Plans Only, Including Certain HRAs)
Employers that sponsor self-insured health plans must pay fees that fund the Patient-Centered Outcomes Research Institute (PCORI). These fees apply to self-funded medical plans and health reimbursement arrangements (HRAs).
Importantly, HRAs that are integrated with fully insured group medical plans are also subject to PCORI fees, even though the underlying medical coverage is insured. However, an HRA that is integrated with a self-insured medical plan generally does not incur a separate fee if both the HRA and the medical plan share the same plan sponsor and plan year.
Employers report and pay PCORI fees annually using IRS Form 720, due by July 31 of the year following the end of the plan year.
Deadline: July 31, 2026
Additional Considerations
Midyear is also a good opportunity for employers to:
- Review internal recordkeeping practices
- Confirm vendor support for required reporting
- Ensure all required participant notices—both at enrollment and ongoing—have been properly distributed