2026 Annual Reporting & Required Benefit Notices
As renewal season approaches, employers should review required employee notices, benefit plan documentation, reporting obligations, and administrative processes for the 2026 plan year. Organized planning helps reduce compliance risk, improve employee communication, and prevent costly corrections later.
Final Chance to File 1094-1095-C on Time
The IRS 1094-1095-C filing deadline is fast approaching. Delaying further can lead to missed deadlines, costly penalties, and unnecessary compliance issues.
- Avoid penalties: Late filings can lead to significant IRS fines.
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- Reduce stress: Filing now means fewer headaches and greater confidence in compliance.
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Call ACACSS NowRequired Annual Notices to Employees
These are the core annual health and welfare notices employers should review and distribute as applicable for the 2026 plan year.
CHIP Notice
The Children’s Health Insurance Program notice informs employees about possible eligibility for premium assistance through state CHIP or Medicaid programs.
- Provide to employees residing in states offering premium assistance.
- Timing is flexible, but it is often distributed with other annual notices.
- Delivery methods generally mirror Medicare Part D notice rules.
Medicare Part D Creditable Coverage Notice
This notice tells Medicare Part D eligible individuals whether the employer’s prescription drug coverage is creditable compared with Medicare Part D.
- Must be provided annually by October 15.
- Best practice is to provide to all employees, even if only certain individuals are Part D eligible.
- May be distributed by paper or electronically under ERISA delivery rules.
WHCRA Notice
The Women’s Health and Cancer Rights Act notice informs participants and beneficiaries about coverage for reconstructive surgery and related benefits following mastectomy.
- Required upon enrollment and annually.
- Must be provided to all participants and beneficiaries.
- Separate notice may be required when beneficiaries live at different addresses.
Open Enrollment Distribution Review
Annual notice season is also the right time to confirm that employee communication materials are accurate, complete, and going to the right audiences.
- Include active employees, COBRA participants, and retirees where applicable.
- Bundle notices with open enrollment communications when appropriate.
- Confirm electronic delivery standards are being met.
Other Required Notices and Timing Rules
These notices may still be required, but they are not generally distributed every year in the same way as CHIP, Medicare Part D, and WHCRA.
HIPAA Special Enrollment Notice
Employers must provide this notice at or before an employee’s initial opportunity to enroll. It is not required to be distributed annually.
Primary Care Provider Patient Protection Notice
Required when a group health plan requires the designation of a primary care provider. This notice should be provided with the SPD or similar plan materials.
Since 2022, this notice applies to both grandfathered and non-grandfathered plans, but there is no annual distribution requirement.
ADA Wellness Program Notice
Employers offering wellness programs that involve medical examinations or disability-related inquiries must provide this notice before employees share health information.
There is no specific annual distribution rule, but it should be reviewed whenever the program or enrollment process is updated.
ACA Exchange Notice
This notice is provided to new hires to explain Health Insurance Marketplace options and related information.
CAA Surprise Billing Notice
This notice is generally required to be posted on a public-facing website so participants can understand surprise billing protections and balance billing restrictions.
COBRA Initial Notice
The COBRA initial notice must generally be provided within 90 days of plan enrollment.
HIPAA Notice of Privacy Practices
This notice is generally provided upon enrollment and then again at least once every three years, depending on the plan and administration structure.
Newborns’ and Mothers’ Health Protection Act Notice
Employers should confirm this notice is included where applicable and that all related plan communications remain consistent with current plan design.
Renewal Time Checklist for Employers
As your renewal approaches, it is the ideal time to align plan design, documentation, administration, payroll settings, enrollment materials, and notice delivery with federal and state requirements. The checklist below highlights key compliance priorities.
Plan Design & Documentation
- Review and update wrap plan documents, SPDs, cafeteria plan documents, and SBCs to reflect current offerings and service providers.
- Review employee and dependent eligibility rules, including leave of absence administration, for consistency across documents.
- Evaluate benefit expansions or exclusions for ACA, MHPAEA, and nondiscrimination compliance.
- Update FSA, HSA, HRA, and DCAP limits for the upcoming year.
- Confirm carryovers, grace periods, and spend-down provisions are correctly described.
- Review grandfathered status if applicable.
Eligibility Tracking
- Confirm measurement and stability periods are properly programmed in payroll and benefit administration systems.
- Review waiting period rules and ensure break in service and rehire provisions are correctly set up.
- Audit eligibility logic to reduce enrollment errors before the new plan year.
Contributions & Affordability
- Ensure employee-only medical contributions satisfy an ACA affordability safe harbor for applicable large employers.
- Confirm pre-tax and after-tax deductions are correctly coded in payroll.
- Review taxable benefit items such as disability premiums, life insurance over $50,000, domestic partner coverage, and owner-related taxation issues.
- Audit payroll and benefit systems to verify contribution accuracy.
- Update income-based benefit levels such as life and disability insurance.
Enrollment Materials & Notices
- Clarify open enrollment timing and whether enrollment is passive or active.
- Distribute open enrollment materials and required annual notices including SBC, WHCRA, CHIP, and Medicare Part D.
- Remember to provide applicable materials to COBRA participants and retirees, not just active employees.
- Update and collect employee attestations where needed, such as HRA integration, opt-out arrangements, ICHRA integration, outside HDHP coverage, or wellness requirements.
Practical reminder: Renewal season is not just about rates and plan design. It is also the best time to confirm that documents, systems, carriers, payroll settings, and employee communications all align before the new plan year begins.
Need Help Reviewing Annual Notices or Renewal Compliance?
Omnia Benefit Partners can help employers organize annual reporting requirements, review benefit notices, support renewal planning, and improve employee communication before deadlines become problems.
Employee Notices & Annual Reporting Checklist
Use this interactive checklist to review common employee notice and annual reporting requirements tied to employer-sponsored health plans. It is designed to help employers stay organized around distribution timing, plan documentation, enrollment communication, and required disclosures.
How to Use This Checklist
- Review each section before open enrollment and plan renewal.
- Confirm who is responsible for preparing and distributing each notice.
- Coordinate timing with payroll, HR, brokers, carriers, TPAs, and COBRA administrators.
- Document your process so annual tasks are easier to manage year to year.
Key Review Areas
- Annual notices that should be revisited each plan year
- Enrollment notices tied to new eligibility or new hires
- Plan documentation that should be updated and redistributed as needed
- Reporting forms such as 1095-B and 1095-C
Annual Reporting Forms
Review year-end ACA reporting responsibilities and confirm whether your carrier, payroll partner, benefits administrator, or internal team is supporting distribution and filing.
1095-B
Complete and distribute Form 1095-B where applicable for smaller level funded or self-funded arrangements and confirm carrier support when relevant.
1095-C
Complete and distribute Form 1095-C for applicable large employers and confirm your ACA reporting workflow is in place before deadlines arrive.
Annual Employee Notices
These items are commonly reviewed and distributed each year as part of open enrollment, annual compliance review, or plan year preparation.
Children’s Health Insurance Program (CHIP) Notice
Distribute the CHIP notice annually before the start of the plan year where applicable.
Medicare Part D Creditable or Non-Creditable Coverage Notice
Confirm prescription drug coverage status and distribute the notice to Medicare-eligible individuals, or more broadly if you prefer a simpler process.
Women’s Health and Cancer Rights Act (WHCRA) Notice
Provide this notice annually and upon enrollment to explain coverage related to mastectomy reconstruction and related services.
ADA Wellness Program Notice
When a wellness program involves medical exams or medical questionnaires, participants must receive notice before releasing information.
HIPAA Wellness Program Notice
Review wellness-related HIPAA notice requirements where your plan design triggers them.
USERRA Notice
Review military leave rights notice distribution and display practices as part of your annual compliance process.
New Hire and Initial Enrollment Notices
These notices are commonly tied to hire date, initial eligibility, enrollment start, or a qualifying event rather than annual open enrollment.
Exchange Notice
Provide the Marketplace or Exchange notice to new hires shortly after employment begins.
HIPAA Notice of Special Enrollment Rights
Provide this notice at or before the time an employee is first offered the opportunity to enroll in the group health plan.
COBRA Initial Notice
Confirm the COBRA initial notice process is being triggered on time for covered participants.
ICHRA Notice
Employers offering an Individual Coverage HRA should confirm the ICHRA notice is delivered far enough ahead of the plan year or new employee application timing.
COBRA, Claims, and Participant Rights
These items often involve qualifying events, claims administration, website display obligations, or participant communication rights.
COBRA Notice and Election Form
Following a qualifying event, confirm the COBRA election notice is issued within required timeframes and that outsourcing relationships are documented.
Explanation of Benefits (EOB)
Review how your carrier or TPA handles EOB delivery and participant communication for claims processing.
No Surprise Billing Model Notice
Review how the notice is posted or made available electronically and confirm plan participants can access it when needed.
Michelle’s Law Notice
Confirm the notice is furnished when student status certification requirements affect dependent coverage.
Plan Documents and Ongoing Disclosures
These are the core documents and notices employers should monitor as part of plan governance, participant communication, and ongoing compliance administration.
Summary of Benefits and Coverage (SBC)
Distribute the SBC during open enrollment and when employees first become eligible during the plan year.
Glossary of Health Coverage and Medical Terms
This is generally provided with the SBC and should be available to health-insurance eligible employees during enrollment periods.
HIPAA Notice of Privacy Practices
Make sure your plan privacy notice is delivered upon enrollment, upon request, after material revisions, and with the required periodic reminder cycle.
Summary Plan Description (SPD)
Review whether new plan creation, participant eligibility, plan amendments, or elapsed update periods trigger SPD distribution.
Summary of Material Modifications (SMM)
When plan changes are adopted, review whether an SMM should be distributed to participants.
Summary Annual Report (SAR)
Review whether your plan files Form 5500 and whether a Summary Annual Report should be distributed to participants.
Newborns’ and Mothers’ Health Protection Act Notice
Confirm this notice language is addressed in the SPD or related plan materials.
Mental Health Parity and Addiction Equity Act Notice
Review this requirement if your plan is claiming the increased cost exemption and offers relevant mental health or substance use disorder benefits.