Retirement Deadline Checklist for March 2022

The Executive Benefits Team at OneDigital is pleased to share the following report, prepared by the Employee Benefits group at Isler Dare PC.

As we enter March, we want to help you keep a few retirement deadlines in mind.

Deadline March 1, 2022

• File DOL Form M-1 for MEWA[i]s
• Disclose “creditable coverage” status for prescription drug coverage to Medicare Part D individuals to CMS[ii] using online form
• Report offers of coverage to full-time employees on Form 1095-C and/or self-insured coverage on Forms 1095-C or 1095-B
• District of Columbia and New Jersey employers must distribute ACA[iii] information returns to their respective residents to satisfy requirements regarding their individual health coverage mandates

Deadline March 15, 2022

• Deadline to apply to the IRS for waiver of the minimum funding standard for defined benefit and money purchase pension plans
• Process corrective distributions to “cure” failed 2021 ADP/ACP [iv]tests for 401(k) plans to avoid paying 10% excise tax (a later June 30 deadline applies to 401(k) plans with eligible automatic contribution arrangements)
• Fund all 2021 company contributions to retirement plans by due date for corporate tax return to deduct contributions for 2021 tax year (unless Form 7004 has been filed to extend due date for corporate tax return, permitting funding by September 15)
• File Form 8928 to report excise taxes for noncompliance with certain group health plan requirements (unless Form 7004 has been filed to extend due date for corporate tax return, permitting filing by September 15)

Deadline March 31, 2022

• Receive elections from eligible ESOP[v] participants to diversify a portion of their ESOP accounts
• Confirm retirement plan recordkeepers have filed Forms 1099-R with the IRS, if filing electronically
• File ACA information reporting returns for 2021 with the IRS, if filing electronically
• File Form 5330 to report and pay excise taxes for excess 2020 plan year ADP/ACP contributions that were not timely corrected in 2021 (or file Form 5558 to request extension of up to six months to file)
• File Retiree Drug Subsidy (RDS) reconciliations with CMS for 2020 plan year
• California employers must submit ACA information returns to the California Franchise Tax Board to satisfy California individual health coverage mandate requirements
• New Jersey employers must submit ACA information returns to the New Jersey Division of Revenue and Enterprise Services to satisfy New Jersey individual health coverage mandate requirements
• Rhode Island employers must submit ACA information returns to the Rhode Island Department of Revenue, using the Division of Taxation webpage, to satisfy Rhode Island individual health coverage mandate requirements

[i] Multiple Employer Welfare Arrangements

[ii] Center for Medicare and Medicaid Services

[iii] Affordable Care Act

[iv] Actual Deferral Percentage/Actual Percentage Plan

[v] Employee Stock Ownership Plans