Employee Benefit Plans End-Of-Year Checklist – What Employers Need to Know

By Kara Brunk

Fall is here, which means open enrollment is coming up and end-of-year deadlines are right around the corner. As we quickly approach the end of 2017 and the start of a new year, here are some deadlines that employers will want to keep in mind for their welfare benefit and retirement plans:

Welfare Benefit Plans

November 1, 2017 

• If your plan’s open enrollment is approaching, you should prepare and distribute enrollment materials, such as the Summary of Benefits and Coverage (SBC).
• Remember, a new SBC template applies to open enrollment periods beginning on and after April 1, 2017.  For plans that do not use an annual open enrollment period, the new template is required beginning on the first day of the first plan year that begins on or after April 1, 2017.

December 31, 2017 

• Annual Notices - WHCRA and CHIP notices must be distributed annually. These notices are often distributed with open enrollment materials.

 January 31, 2018 

• Deadline to furnish Form 1095-C to employees.

February 28, 2018 

• Deadline to file Forms 1094/1095, if filing on paper (or April 2, if filing electronically). 

Retirement Plans

December 1, 2017 

• Annual Notices for Defined Contribution Plans
  • Safe Harbor Notice – If your 401(k) or 403(b) plan will use safe harbor ADP/ACP testing for the 2018 plan year, you must distribute a safe harbor notice to all eligible employees no later than December 1, 2017.
  • ACA, QACA, EACA and QDIA Notices – If your defined contribution plan includes an automatic contribution arrangement (either an ACA, QACA or EACA) and/or qualified default investment alternative (QDIA), you must provide a notice to eligible employees, and in the case of QDIA, participants or beneficiaries who could become subject to the QDIA, no later than December 1, 2017.
  • Participant-Level Fee Disclosures – General information about the plan and potential administrative and individual costs must be furnished to participants and beneficiaries at least annually (meaning at least once in any 14-month period).

December 31, 2017 

• Plan Amendments – Plan sponsors should consider whether plan amendments are needed to reflect desired design or operational changes, to address a disqualifying provision, or to otherwise comply with regulatory or statutory requirements.
  • 2017 Plan Year Design Changes – Generally, any discretionary plan design changes implemented during the 2017 plan year must be adopted by December 31.
  • 2018 Plan Year Design Changes – Discretionary plan design changes anticipated for 2018 that will reduce future benefits or that are otherwise required to be adopted prospectively (such as changes to a safe harbor 401(k) plan, with limited exceptions) must be adopted by December 31.
  • Important! For defined benefit pension plans that offer bifurcated benefit distribution options (i.e., the option to receive a portion in an annuity form and the remainder in an accelerated form), plan sponsors must properly amend the plan by December 31, 2017 to receive relief from the anti-cutback rule.
• Required Minimum Distributions – RMDs must be made annually by December 31 (as a reminder, the initial RMD must be received by April 1 following the calendar year in which the participant reaches age 701/2, or if later, the calendar year in which the participant who is not a more-than-5% owner of the employer retires).

 January 1, 2018 

• Effective January 1, 2018, new adjusted dollar limitations apply to benefits and contributions under qualified retirement plans. These increases include:
  • Code § 415(b)(1)(A) limit on the annual benefit under a defined benefit plan increased from $215,000 to $220,000.
  • Code § 415(c)(1)(A) limit for defined contribution plans increased from $54,000 to $55,000.
  • Code § 402(g) elective deferral limit increased from $18,000 to $18,500.
  • Code §§ 401(a)(17), 404(l), 408(k)(3)(C) and 408(k)(6)(D)(ii) annual compensation limit increased from $270,000 to $275,000.

A full list of 2018 dollar limitations can be found here.

February 28, 2018 

• Deadline for filing Form 1099-R to report distributions made in 2017 (electronic filing deadline is April 2).

March 15, 2018 

• Deadline for calendar year plans to process corrective distributions and contributions for failed 2017 ADP and ACP tests without a 10% excise tax (extended to June 30 for plans using automatic enrollment).

April 2, 2018 

• Deadline for electronic filing of Form 1099-R to report distributions made in 2017.