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Your End-of-Year Benefits Compliance Action Plan

As 2026 winds down, HR and benefits administrators face compliance deadlines that can't be missed. Finishing these tasks now helps protect your business from penalties and audit exposure and keeps employees clear on their coverage. Here's what's on the calendar.

October:

Creditable Coverage Notices must go out before October 15. They go to every Medicare-eligible individual who is eligible for your plan's prescription drug coverage, including active employees, COBRA beneficiaries, and covered spouses and dependents. When in doubt, send the notice. If you filed a Form 5500 extension, that deadline is also October 15, and missing it can bring significant Department of Labor penalties. October is also a good time to audit your COBRA notices for timeliness and accuracy. You can then calculate your 2027 COBRA rates (up to 102 percent of plan cost) to share with participants.

November–December:

Update COBRA premiums in your billing system and send any open enrollment reminders . Make sure your Section 125 plan documents reflect this year's changes, and run nondiscrimination testing for your FSAs and cafeteria plan. Confirm how you'll handle unused FSA balances , whether through carryover, a grace period, or a runout period, and tell employees so they can plan ahead. Finalize your ERISA plan-year closeout documentation , and update your Summary Plan Description if your plan changed. Then review your employee handbook for new state and local requirements.

Before Year-End:

If you're an Applicable Large Employer, start gathering data for your 2026 ACA reporting . Forms 1095-C are due to employees by March 2, 2027, and electronic filing with the IRS is due March 31, 2027. Confirm that you've tracked full-time status accurately for each month. Also check that your lowest-cost self-only plan meets the 2026 affordability threshold of 9.96 percent.

Don't forget your annual creditable coverage disclosure to CMS . It's due within 60 days after the start of your plan year and within 30 days of any change in status.

Tackle one section at a time, and reach out to us if you need guidance on the requirements specific to your business.

The ACA Marketplace Open Enrollment Period (OEP) is just around the corner. In most states Open Enrollment for 2027 coverage runs from November 1 through January 15, giving individuals and families an opportunity to enroll in coverage, renew an existing plan or choose a different option for the year ahead. Enrollment deadlines can vary by state, so contact our agency to confirm the exact dates that apply to you.

Now is a good time to start getting prepared. Think about what may be different for your household in 2027, including expected income, household size, health care needs, prescriptions, and preferred doctors or other health care providers. If you already have Marketplace coverage, watch for notices from both the Marketplace and your insurance company regarding your 2027 coverage. Keep those notices handy—they can contain important information about your current plan, changes for the new year, and steps you may need to take.

Even if you’re happy with your current coverage, it’s worth reviewing your options once 2027 plans are available. Plans, premiums and benefits can change from year to year, and your own needs may have changed as well. When comparing plans, look beyond the monthly premium and consider deductibles and other out-of-pocket costs, whether your doctors and other providers participate in the plan’s network, and whether your prescriptions and preferred pharmacies are covered. If you receive financial assistance through the Marketplace, start thinking now about your 2027 income estimates and household information so the Marketplace can determine the savings for which you may qualify.

Get a head start on Open Enrollment. Contact our agency to schedule an appointment for November 1 or later to review your 2027 Marketplace coverage options. When Open Enrollment begins, we can help you compare available plans, review costs and coverage, and consider which option may fit your needs and budget.

October is a critical time to review your Medicare coverage. Starting October 1, you can begin comparing your current Medicare coverage — whether Original Medicare, Medicare Advantage, or a Medicare drug plan — against other options available for the coming year. Start by reviewing your plan's Annual Notice of Change (ANOC), which your plan mailed in September. It explains changes to your plan's costs and coverage that will take effect January 1. Pay attention to any changes that could affect you, and we can help you compare your current coverage with other available options to see how well it may meet your needs in the coming year.

Beginning October 15, Medicare's Annual Enrollment Period (AEP) officially opens. During this time, you can enroll in, switch or drop a Medicare Advantage or Medicare prescription drug plan, or switch between Original Medicare and Medicare Advantage. AEP continues through December 7, and changes made during this period generally take effect January 1.

Contact our office today to schedule time to walk through your choices. We will help you make a confident decision before AEP ends on December 7.