This SOP defines the annual compliance filing and notice deadlines for each participating employer plan under the Unity Care Member Plan Master Trust. Deadlines apply at the individual employer plan level — each employer is responsible for its own plan's compliance obligations under ERISA, ACA, HIPAA, and related federal law. Unity Care Solutions, LLC (Program Manager) coordinates and assists; it does not absorb employer-level fiduciary obligations.
Applies to all employer plans participating in the Unity Care Member Plan Master Trust. Covers annual federal compliance filings, participant notices, and related regulatory submissions. Does not cover state-specific requirements (see OPS-SOP-022 for regulatory monitoring) or day-to-day operational compliance (see SOPs 001–012).
Q1 — January/February/March
| Deadline | Filing / Notice | Filed By | Via | Notes |
|---|---|---|---|---|
| Jan 31 | W-2 Box 12 DD Reporting — employer-sponsored health coverage cost | Each Employer (HR) | Payroll system | Required for employers with 250+ W-2 filers. Coordinate with HR/payroll. EMPLOYER |
| Jan 31 | ACA 1095-C/1094-C employee copies due to employees | Each Employer (ALE) | Spartan Wealth coordinates | Applicable Large Employers (50+ FTEs) only. Spartan Wealth filing support. EMPLOYER |
| Mar 31 | ACA 1094-C/1095-C electronic filing with IRS | Each ALE Employer | IRS FIRE system / Spartan Wealth | Electronic required if 10+ forms. Paper deadline Feb 28. CRITICAL |
Q2 — April/May/June
| Deadline | Filing / Notice | Filed By | Via | Notes |
|---|---|---|---|---|
| Apr 1 | SPD distribution — new plan year or material modification | Each Employer / Operations | Allied / direct distribution | Must be distributed within 90 days of plan year start (1/1 plan = Apr 1). CRITICAL |
| May 1 | PCORI fee payment (Form 720) | Each Employer Plan | IRS / Finance | $3.22 per covered life (2025 plan year). Based on average covered lives. Finance calculates from Allied enrollment data. EMPLOYER |
| Jun 1 | RxDC (Prescription Drug Data Collection) — CMS submission | Allied (current year) / Operations coordinates | CMS Health Insurance Oversight System (HIOS) | Allied files current plan year. BPA filed 2025 prior year (Nuwell only). New groups: Allied files from 2026 forward. CRITICAL |
Q3 — July/August/September
| Deadline | Filing / Notice | Filed By | Via | Notes |
|---|---|---|---|---|
| Jul 31 | Form 5500 (+ SAR distribution 9 months after plan year end, or 2 months after 5500 filing) | Each Employer (Plan Admin) | DOL EFAST2 / Legal Counsel | Due 7 months after plan year end (12/31 plan = Jul 31). Extension available (Form 5558 by Jul 31 → extends to Oct 15). Eric Gregory coordinates. CRITICAL |
| Sep 30 | SAR (Summary Annual Report) distribution to participants | Each Employer / Operations | Direct distribution | Must be distributed within 2 months of 5500 filing (if filed by Jul 31 → SAR due Sep 30). EMPLOYER |
Q4 — October/November/December
| Deadline | Filing / Notice | Filed By | Via | Notes |
|---|---|---|---|---|
| Oct 14 | Medicare Part D Creditable Coverage Notice to Medicare-eligible participants | Each Employer / Operations | Allied / direct mail or electronic | Required annually before Oct 15 open enrollment period. Allied can distribute with enrollment materials. EMPLOYER |
| Oct 15 | Form 5500 extended filing deadline (if Form 5558 extension filed by Jul 31) | Each Employer (Plan Admin) | DOL EFAST2 / Legal Counsel | Hard deadline — no further extensions available. CRITICAL |
| Dec 31 | CAA Gag Clause Attestation | Allied (on behalf of plan) | CMS HIOS | Allied files annually. Operations confirms filing was completed. ALLIED FILES |
| Dec 31 | CAA Broker Compensation Disclosure to plan sponsor | Spartan Wealth / SRS | Direct to each employer | Required from brokers receiving $1,000+ per enrolled employee annually. Each employer must receive disclosure. Operations tracks receipt. BROKER FILES |
| Ongoing / Annual | MHPAEA Comparative Analysis — available within 10 business days of DOL request | Each Employer / Legal Counsel | Prepared in advance; provided on demand | 75–100 page analysis. DOL can request with 10 business day turnaround. Must be prepared proactively — not reactive. Commission Eric Gregory. CRITICAL — MUST BE PREPARED IN ADVANCE |
| Notice | When Required | Distributed By |
|---|---|---|
| Summary Plan Description (SPD) | Within 90 days of enrollment; annually if material changes | Operations / Allied |
| Summary of Benefits and Coverage (SBC) | Before open enrollment; within 7 days of request | Allied / Operations |
| Summary of Material Modification (SMM) | Within 60 days of material plan change | Operations / Legal Counsel |
| HIPAA Privacy Notice | Upon enrollment; every 3 years (reminder) | Operations / Allied |
| COBRA Election Notice | Within 14 days of qualifying event | Varipro (COBRA administrator) |
| CHIP Notice | Annually (before plan year) | Operations / Allied |
| Women's Health & Cancer Rights Act (WHCRA) Notice | Annually and upon enrollment | Operations / Allied |
| Newborns' & Mothers' Health Protection Act Notice | Upon enrollment; in SPD | Included in SPD |
| MHPAEA Notice (parity disclosures) | Upon request; in SPD | Legal Counsel / Operations |
| Exchange / Marketplace Notice | At hire | Each Employer (HR) |
| NSA Patient Protections Notice | Annually; upon enrollment | Allied / Operations |
| Vendor | Primary Compliance Role |
|---|---|
| Allied Benefit Systems (TPA) | RxDC filing, CAA gag attestation, NSA IDR management, claims data for 5500/PCORI, SBC/SPD distribution support |
| ProAct (PBM) | Pharmacy claims data for RxDC; Rx rebate reporting (via Leaf Health) |
| Varipro (COBRA) | COBRA notices, election processing, premium collection |
| Spartan Wealth (Broker) | ACA 1094-C/1095-C filing support (ALEs); CAA broker compensation disclosures |
| SRS (Program Manager) | Trust accounting; fiduciary coordination; reinsurance program management |
| Dickinson Wright PLLC | Form 5500 preparation, MHPAEA analysis, ERISA legal review, material SOP/notice changes |
| Bill Kropkoff / ERISA Group | Independent annual fiduciary fee review (prohibited transaction mitigation) |
Operations maintains a master compliance calendar (location: [TBD — Teams / shared drive]) updated at the start of each plan year. The calendar includes: