2025 HR Compliance Calendar

S R O S I V 2025 D A HR COMPLIANCE T I CALENDAR F E N E B D H L

January 2025 Sun Mon Tue Wed Thu Fri Sat 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 A B C D A File and Furnish Forms W-2 your company was timely in depositing all taxes when they File Forms W-2 with the Social Security were due, the filing deadline is extended to Feb. 10, 2025. Administration by Jan. 31, 2025. Companies may request a 30-day filing extension using Form 8809, but extensions D File Form 940, Employer’s Annual are not automatic and will only be granted in limited cases FUTA Tax Return for extraordinary circumstances or catastrophes. Forms W-2 must also be furnished to employees on or before File Form 940 with the IRS by Jan. 31, 2025, to report Jan. 31, 2025. taxable Federal Unemployment Tax Act (FUTA) wages paid in 2024. If your company deposited all its FUTA tax when it File and Furnish Forms 1099-NEC, was due, the filing deadline is extended to Feb. 10, 2025. B Nonemployee Compensation File Forms 1099-NEC with the IRS by Jan. 31, 2025, if your Compliance Reminders company made payments totaling $600 or more for As 2025 begins, review your company’s compliance with services performed by nonemployees, such as federal, state and local employment laws. This review independent contractors, in 2024. A 30-day filing should include: extension may be requested by using Form 8809, but • Checking that workplace posters are up to date; extensions are not automatic and will only be granted in • Verifying minimum wage and overtime requirements limited cases for extraordinary circumstances or and updating the wage base limit for withholding; catastrophes. Companies must also furnish statements to • Confirming employee leave policies are consistent the non-employees on or before Jan. 31, 2025. with federal, state and local leave requirements; • Reviewing any new fair employment law protections File Form 941, Employer’s Quarterly and incorporating changes into employee training; C Federal Tax Return • Updating the employee policies as necessary; File Form 941 with the IRS by Jan. 31, 2025, to report the • Making a schedule for any required workplace federal income tax, Social Security tax and Medicare tax training, such as sexual harassment training; and you withheld from your employees’ pay during the fourth • Reviewing recruitment and compensation practices to quarter of 2024 (October, November and December). If ensure they are consistent with any applicable pay transparency laws.

February 2025 Sun Mon Tue Wed Thu Fri Sat A 1 17 B 28 C D A Post OSHA Form 300A (Summary of applies to filing paper versions of these forms; the Work-related Injuries and Illnesses) deadline for electronic filing is March 31, 2025. Almost all Post OSHA Form 300A by Feb. 1, 2025, in an area in the employers subject to ACA reporting are required to file workplace where employee notices are customarily their returns electronically. Paper filing is only an option for posted. This form, which summarizes workplace data from very small employers (i.e., employers who file fewer than 2024, must remain on display until April 30, 2025. This 10 information returns during the year). A hardship waiver requirement does not apply to companies with 10 or fewer may be requested from the electronic filing requirement employees or employers in a partially exempt industry. by submitting Form 8508 to the IRS. Reporting entities are encouraged to submit Form 8508 at least 45 days before Forms W-4 That Claim Exemption the due date of the returns. B From Withholding for 2024 Expire File ACA Forms 1094-B and 1095-B To continue to be exempt from withholding, an employee D (Paper Filing Deadline) must provide a new Form W-4 claiming exempt status by Paper Filing Is No Longer an Option for Most Employers Feb. 15. However, because the deadline falls on a The deadline for non-ALEs with self-insured health plans weekend, it is extended to the next business day, which is to file Feb. 17, 2025. If the employee doesn’t give you a new Forms 1094-B and 1095-B on paper with the IRS is Form W-4 by the deadline, withhold tax as if the employee Feb. 28, 2025. This deadline only applies if your company is single or married and filing separately without any files paper versions of these forms; the deadline for allowances. electronic filing is March 31, 2025. Almost all employers subject to ACA reporting are required to file their returns ACA Forms 1094-C and 1095-C electronically. Paper filing is only an option for very small C (Paper Filing Deadline) employers (i.e., employers who file fewer than 10 Paper Filing Is No Longer an Option for Most Employers information returns during the year). A hardship waiver The deadline for applicable large employers (ALEs) to file may be requested from the electronic filing requirement Affordable Care Act (ACA) Forms 1094-C and 1095-C on by submitting Form 8508 to the IRS. Reporting entities are paper with the IRS is Feb. 28, 2025. This deadline only encouraged to submit Form 8508 at least 45 days before the due date of the returns.

March 2025 Sun Mon Tue Wed Thu Fri Sat A 1 2 3 B C D E Submit the Medicare Part D Labor (DOL) each year by March 1. However, because the A Disclosure to CMS (Calendar-year deadline falls on a weekend, it is extended to the next Plans Only) business day, which is March 3, 2025. In general, MEWAs Submit an online form to the Centers for Medicare and are arrangements, including association health plans, that Medicaid Services (CMS) indicating whether your health offer benefits to the employees of two or more different plan’s prescription drug coverage is creditable or non- employers. A 60-day automatic extension may be creditable. The deadline for submitting this annual requested by the filing deadline. disclosure is 60 days from the beginning of the plan year. For calendar-year health plans, the deadline for the annual D Provide ACA Form 1095-C to online disclosure is March 1, 2025. Employees Furnish Form 1095-C to employees by March 3, 2025, if B Submit Electronic Reports to OSHA your company is an ALE. These statements were required Submit OSHA Form 300A by March 2, 2025, for to be provided on or before Jan. 31; however, the IRS establishments with at least 250 employees who are extended this deadline by 30 days. With the extension, the required to create and maintain OSHA records. deadline is normally March 2. However, because the Establishments with 20-249 employees in certain high- deadline falls on a weekend, the statements must be hazard industries must also submit this data by March 2, furnished by the next business day, which is March 3, 2025. Employers with 100 or more employees in certain 2025. high-hazard industries must submit additional injury and illness information from their OSHA Forms 300 and Starting with ACA reporting for 2024, ALEs may use an 301. Companies use OSHA’s Injury Tracking Application to alternative method of furnishing Form 1095-C that submit their reports. requires these statements to be provided upon request only. ALEs must give individuals timely notice of this File Form M-1 for MEWAs option, in accordance with requirements set by the IRS. C Administrators of multiple employer welfare Requests must be fulfilled by Jan. 31 of the year following arrangements (MEWAs) that offer medical benefits must the calendar year to which the return relates or 30 days electronically file Form M-1 with the U.S. Department of after the date of the request, whichever is later.

March Deadlines (Cont.) E Provide ACA Form 1095-B to Employees Furnish Form 1095-B to employees by March 3, 2025, if your company is a non-ALE with a self-insured health plan. These statements were required to be provided on or before Jan. 31; however, the IRS extended this deadline by 30 days. With the extension, the deadline is normally March 2. However, because the deadline falls on a weekend, the statements must be furnished by the next business day, which is March 3, 2025. Non-ALEs may use an alternative method of furnishing Form 1095-B that requires these statements to be provided upon request only. Non-ALEs must give individuals timely notice of this option, in accordance with requirements set by the IRS. Requests must be fulfilled by Jan. 31 of the year following the calendar year to which the return relates or 30 days after the date of the request, whichever is later. F Electronically File ACA Forms 1094-C and 1095-C File Forms 1094-C and 1095-C with the IRS by March 31, 2025, if your company is an ALE. Employers may request an automatic 30-day extension by filing Form 8809 by the filing due date. Most employers subject to ACA reporting are required to file their returns electronically. Paper filing is only an option for very small employers (i.e., employers who file fewer than 10 information returns during the year). The paper filing deadline is Feb. 28, 2025. G Electronically File ACA Forms 1094-B and 1095-B File Forms 1094-B and 1095-B with the IRS by March 31, 2025, if your company is a non-ALE that sponsors a self- insured health plan. Employers may request an automatic 30-day extension by filing Form 8809 by the filing due date. Most employers subject to ACA reporting are required to file their returns electronically. Paper filing is an option only for very small employers (i.e., employers who file fewer than 10 information returns during the year). The paper filing deadline is Feb. 28, 2025. G Monitor the Deadline for Filing the EEO-1 Report With the EEOC Private-sector employers with 100 or more employees and federal contractors with 50 or more employees meeting certain criteria must submit demographic workforce data to the Equal Employment Opportunity Commission (EEOC) each year as part of the EEO-1 data collection. In general, these reports are due by March 31 each year. However, the EEOC has delayed this deadline in previous years.

April 2025 Sun Mon Tue Wed Thu Fri Sat 30 A B Remove OSHA Form 300A B File Form 941, Employer’s Quarterly A (Summary of Work-related Injuries Federal Tax Return and Illnesses) File Form 941 with the IRS by April 30, 2025, to report the Remove your company’s OSHA Form 300A posting at any federal income tax, Social Security tax and Medicare tax time on or after April 30, 2025. This form, which you withheld from your employees’ pay during the first summarizes workplace data from 2024, must be posted quarter of 2025 (January, February and March). If your from Feb. 1, 2025, until April 30, 2025. This posting company was timely in depositing all taxes when they requirement does not apply to companies with 10 or were due, the filing deadline is extended to May 10, 2025. fewer employees or employers in a partially exempt However, since the extended deadline falls on a weekend, industry. the extended deadline is the next business day, which is May 12, 2025.

May 2025 Sun Mon Tue Wed Thu Fri Sat No Compliance Due Dates in May… It’s a Great Month to Take a Vacation!

June 2025 Sun Mon Tue Wed Thu Fri Sat 1 A A Submit Prescription Drug Data Collection Report Confirm that your health plan’s annual prescription drug data collection report is submitted to CMS by June 1, 2025. Employer-sponsored health plans and health insurance issuers must annually report information about prescription drug spending to the federal government. This reporting process is referred to as the “prescription drug data collection” (or “RxDC report”). Most employers rely on third parties, such as issuers, third-party administrators (TPAs) or pharmacy benefit managers, to prepare and submit the RxDC report for their health plans.

July 2025 Sun Mon Tue Wed Thu Fri Sat 31 A B C A File Form 941, Employer’s Quarterly C File Form 5500 for the 2024 Plan Federal Tax Return Year (Calendar-year Plans Only) File Form 941 with the IRS by July 31, 2025, to report the File Form 5500 with the DOL by July 31, 2025, for your federal income tax, Social Security tax and Medicare tax ERISA-covered employee benefit plans that operate on you withheld from your employees’ pay during the second the calendar year unless a reporting exemption applies. quarter of 2025 (April, May and June). If your company was Form 5500 must be filed by the last day of the seventh timely in depositing all taxes when they were due, the filing month following the end of the plan year. For calendar- deadline is extended to Aug. 10, 2025. However, since the year plans, this deadline is July 31. An automatic extension extended deadline falls on a weekend, the extended of 2.5 months may be requested by filing IRS Form 5558 deadline is the next business day, which is Aug. 11, 2025. by the due date. Small welfare benefit plans (fewer than 100 participants) that are fully insured, unfunded, or a combination of insured/unfunded are generally exempt B Report and Pay PCORI Fees (Self- from the Form 5500 filing requirement. insured Health Plans Only) If you have a self-insured health plan, report and pay fees to fund the Patient-Centered Outcomes Research Institute (PCORI) by July 31, 2025. Employers use IRS Form 720 to report and pay PCORI fees.

August 2025 Sun Mon Tue Wed Thu Fri Sat No Compliance Due Dates in August… Use Up the Rest of Your PTO!

September 2025 Sun Mon Tue Wed Thu Fri Sat 30 A B A Provide SAR to Plan Participants B Watch for MLR Rebates (Fully- (Calendar-year Plans Only) if Form Insured Health Plans Only) 5500 Deadline Was Not Extended Employers with insured health plans might receive rebates Provide a summary annual report (SAR) to plan if their issuers did not meet their medical loss ratio (MLR) participants by Sept. 30, 2025, for calendar-year plans if percentage for 2024. Rebates must be provided by Sept. the employee benefit plan’s Form 5500 deadline is not 30 following the end of the MLR reporting year. Employers extended. The SAR must be provided within nine months who receive rebates should consider their legal options of the close of the plan year unless the plan’s Form 5500 for using the rebate. Any rebate amount that qualifies as a deadline is extended. Plans exempt from the annual 5500 plan asset under ERISA must be used for the exclusive filing requirement are not required to provide an SAR. benefit of the plan’s participants and beneficiaries. Also, Unfunded welfare plans are also generally exempt from as a general rule, plan sponsors should use the plan asset the SAR requirement. portion of the rebate within three months of receiving it to avoid ERISA’s trust requirements.

Preparing Open Enrollment Employers with calendar-year plans should start preparing COBRA General Notice for open enrollment for the plan year starting Jan. 1, 2026. Group health plans must provide a written General Notice This process should include reviewing your company’s of COBRA Rights to covered employees within 90 days benefit offerings, working with vendors to make any after their health plan coverage begins. Employers may benefit adjustments, updating benefit limits for 2026 and include the General Notice in their open enrollment preparing employee communications. If your company is materials to ensure that employees who newly enroll an ALE, you also may need to adjust employee during open enrollment receive the notice on a timely contributions based on the ACA’s affordability percentage basis. The DOL has a COBRA Model General Notice for for plan years beginning in 2026. employers to use; In addition, you should consider providing the following bene- fit notices in connection with open enrollment: HIPAA Privacy Notice (self-insured health plans only) Summary of Benefits and Coverage (SBC) The HIPAA Privacy Rule requires self-insured health plans Group health plans and health insurance issuers are to maintain and provide their own privacy notices. Self- required to provide an SBC to applicants and enrollees insured health plans are required to send privacy notices each year at open enrollment or renewal time. Federal at certain times, including to new enrollees at the time of agencies have provided a template for the SBC, which enrollment. Thus, the privacy notice should be included health plans and issuers are required to use; with the plan’s open enrollment materials. Also, at least once every three years, health plans must either Children’s Health Insurance Plan (CHIP) redistribute the privacy notice or notify participants that Annual Notice the privacy notice is available and explain how to obtain a If your group health plan covers residents in a state that copy. The Department of Health and Human Services provides a premium subsidy under a Medicaid plan or (HHS) has model privacy notices for employers to use; CHIP, send an annual notice about the available assistance to all employees residing in that state. The annual CHIP Special Enrollment Rights Notice notice can be provided any time during the year, but it is At or before enrollment, a group health plan must provide often included with the plan’s open enrollment materials. each eligible employee with a notice of their special The DOL has a model notice for employers to use; enrollment rights under HIPAA. This notice is often included in the plan’s SPD or benefits booklet provided by Women’s Health and Cancer Rights Act the issuer or TPA; (WHCRA) Notice Group health plans must provide a notice about the Notice of Patient Protections WHCRA’s coverage requirements at the time of enrollment If a health plan requires participants to designate a and annually after enrollment. The annual WHCRA notice participating primary care provider, the plan or issuer must can be provided at any time during the year, but it is often provide a notice of patient protections whenever the SPD included with the plan’s open enrollment materials. or similar description of benefits is provided to a Employers that redistribute their summary plan participant. This notice is often included in the SPD or descriptions (SPDs) each year can satisfy the annual benefits booklet provided by the issuer or TPA (or notice requirement by including the WHCRA notice in their otherwise provided with enrollment materials). The DOL SPDs. Model language is available in the DOL’s model has a model notice for employers to use; notice guide; Grandfathered Plan Notice SPD Companies with grandfathered health plans must include a An SPD must be provided to new plan participants within statement of the plan’s grandfathered status in plan 90 days of the date their coverage begins. Employers may materials provided to participants describing the plan’s include the SPD in their open enrollment materials to make benefits (such as open enrollment materials). The DOL has sure employees newly enrolled employees receive the a model notice for employers to use. SPD on a timely basis. Also, an employer should include the SPD with its enrollment materials if it includes notices that are required to be provided at the time of enrollment, such as the WHCRA notice;

October 2025 Sun Mon Tue Wed Thu Fri Sat Apply to CMS for the Retiree Drug reimbursement arrangements (QSEHRAs) must provide a A Subsidy (Calendar-year Plans Only) notice to eligible employees regarding the QSEHRA’s The retiree drug subsidy (RDS) is available to certain coverage. This notice must be provided at least 90 days employers who sponsor group health plans covering before the beginning of each plan year. For QSEHRAs that retirees who are entitled to enroll in Medicare Part D but operate on a calendar-year basis, this notice must be elect not to do so. To participate in the RDS program, provided by Oct. 3, 2025, for the upcoming 2026 plan year. eligible employers must submit an application to CMS Provide Medicare Part D Notices to before the beginning of the plan year by a date specified D Plan Participants by CMS (usually about 90 days before the beginning of the Notify Medicare Part D eligible individuals by Oct. 14, plan year). The approximate deadline is Oct. 2, 2025, for 2025, whether the health plan’s prescription drug plan years beginning on Jan. 1, 2026. This deadline may be coverage is creditable or non-creditable. extended by 30 days if CMS grants an extension. Provide ICHRA Notice for 2026 Plan File Form 5500 for the 2024 Plan B Year E Year if Form 5500 Deadline Was Employers that offer individual coverage health Extended reimbursement arrangements (ICHRAs) must provide a File Form 5500 with the DOL by Oct. 15, 2025, if you have notice to eligible employees regarding the ICHRA’s a calendar-year plan and applied for the automatic 2.5- coverage. This notice must be provided at least 90 days month filing extension. before the beginning of each plan year. For ICHRAs that File Form 941, Employer’s Quarterly operate on a calendar-year basis, this notice must be F Federal Tax Return provided by Oct. 3, 2025, for the upcoming 2026 plan year. A model notice is available for employers to use. File Form 941 with the IRS by Oct. 31, 2025, to report the federal income tax, Social Security tax and Medicare tax C Provide QSEHRA Notice for the 2026 you withheld from your employees’ pay during the third Plan Year (Calendar-year quarter of 2025 (July, August and September). If your Plans Only) company was timely in depositing all taxes when they were Employers that offer qualified small employer health due, the filing deadline is extended to Nov. 10, 2025.

November 2025 Sun Mon Tue Wed Thu Fri Sat Compliance Reminders As the end of the year approaches, consider taking the following steps to encourage employees to utilize any unused benefits for 2025: Remind employees about what happens to unused funds in their health flexible spending accounts (FSAs), health reimbursement arrangements (HRAs) and dependent care FSAs at the end of the year. Encourage employees to use their unspent balances in these accounts, especially if unused funds are forfeited at the end of 2025 (calendar-year plans only); and Review employee paid time off (PTO) balances and remind employees of the company’s policy for unused PTO at the end of the year (for example, perhaps your company caps carryovers of unused PTO).

December 2025 Sun Mon Tue Wed Thu Fri Sat 15 Provide SAR to Plan Participants need to provide an attestation. Employers with self- A (Calendar-Year Plans Only) if Form insured health plans can enter into written agreements 5500 Deadline Was Extended with their TPAs to provide the attestation, but the legal responsibility remains with the health plan. Provide an SAR to covered employees by Dec. 15, 2025, if you have a calendar-year plan and the plan’s form 5500 Compliance Reminders deadline was extended. In general, the SAR must be As 2025 comes to a close, review your company’s provided within nine months of the close of the plan year. compliance to ensure that all required activities will be However, if the plan’s Form 5500 deadline is extended, the completed by the end of the year. This review may include SAR must be provided within two months after the close of the following tasks: the extension period. For calendar-year plans, this extended deadline is Dec. 15, 2025. Plans that are exempt • Complete any outstanding annual performance reviews; from the annual 5500 filing requirement are not required to provide an SAR. Unfunded welfare plans are also generally • Confirm that any required workplace employee training will exempt from the SAR requirement. be completed by the appropriate deadline; • Encourage employees to fill out a new Form W-4 for 2026 if they have experienced personal or financial changes B Submit a Gag Clause Attestation that impact their tax withholding; and Employer-sponsored health plans and health insurance issuers must submit attestations of compliance • Confirm that annual nondiscrimination testing has been with the prohibition on gag clauses by Dec. 31 each year. performed for employee benefit plans that are subject to Plans and issuers can submit their attestations through a these testing requirements, including Section 125 CMS website. If the issuer for a fully-insured health plan cafeteria plans, self-insured health plans, health FSAs, provides the attestation, the health plan does not also dependent care FSAs, HRAs, group term life insurance and retirement plans.

Dynamic Deadlines COBRA General Notice FMLA Rights and Responsibilities Notice Provide a general notice of COBRA rights to each covered Each time the eligibility notice is provided, give a notice employee and spouse (if any) within 90 days after their detailing the specific expectations and obligations of the health plan coverage begins. Employers often include this employee and explaining any consequences of a failure to notice in their plan’s open enrollment materials. The DOL meet these obligations. This notice may be accompanied has a model notice for employers to use. by any required certification form. The DOL has a model rights and responsibilities notice, which is included in COBRA Election Notice Form WH-381. Notify qualified beneficiaries of their right to elect continuation coverage under COBRA following a qualifying FMLA Designation Notice event. This notice must be provided no later than 14 days Within five business days of receiving sufficient after the plan’s receipt of the notice of a qualifying event. information to grant or deny FMLA leave, inform the For qualifying events where the employee (or covered employee whether their FMLA leave request is approved. dependent) is not required to notify the employer of the The DOL has a model designation notice (Form WH-382) qualifying event, the election notice must be provided that employers may use. within 44 days of the qualifying event (or loss of coverage, if later). The DOL has a model notice for employers to use. SPD Provide the SPD to new plan participants within 90 days of Notice of COBRA Unavailability when their coverage begins. An updated SPD must be If you deny a request for COBRA continuation coverage (or provided to covered employees at least every five years if for an extension of COBRA continuation coverage), material modifications have been made during that period. provide the individual with a notice of unavailability of If no material modifications have been made, an updated COBRA coverage. The notice must be provided within 14 SPD must be provided at least every 10 years. days after the request for COBRA continuation coverage is received, and it must explain the reason for denying the Summary of Material Modification (SMM) request. An SMM must be provided when there is a material modification in the terms of the plan or any change in the Notice of COBRA Early Termination information required to be in the SPD. As a general rule, If COBRA coverage terminates early, give the qualified the SMM must be provided within 210 days after the close beneficiary a notice of early termination. The notice must of the plan year in which the change was adopted. A explain why the coverage will terminate earlier than the shorter deadline may apply in some circumstances, end of the maximum coverage period, provide the date the depending on the nature of the modification or change. If coverage will terminate and describe any rights the the change is a material reduction in group health plan qualified beneficiary may have to elect other coverage. benefits or services, the deadline for providing the SMM is The notice must be provided as soon as practicable 60 days after the change is adopted. Also, employers must following the decision to terminate coverage early. provide 60 days advance notice of any material modification to plan terms or coverage that takes effect Notice of Insufficient Payment mid-plan year and affects the content of the plan’s SBC. If a qualified beneficiary makes a timely premium payment, The 60-day notice can be provided to participants through but the amount of the payment is short by an insignificant an updated SBC or by issuing an SMM. amount, notify the qualified beneficiary of the shortfall and provide a reasonable period of time (e.g., 30 days) to pay Plan Documents the missing amount. Provide copies of certain plan documents within 30 days after a written request by a participant and beneficiary and General Notice of FMLA Rights have copies available for examination. These documents Post a general FMLA notice where it can be readily seen include the latest SPD, SMMs, Form 5500, trust by employees. Also, provide this notice to employees by agreements and other instruments under which the plan is including it in the company’s employee handbook, if one established or operated. exists, or distributing a copy to each new employee upon hiring. The DOL has a model poster for employers to use. HIPAA Wellness Notice HIPAA’s nondiscrimination rules apply to wellness FMLA Eligibility Notice programs offered in connection with group health plans. When an employee requests FMLA leave, or when you To comply with HIPAA, health-contingent wellness plans learn that an employee’s leave may be for an FMLA- must provide a notice informing employees that there is qualifying reason, notify the employee of their eligibility to an alternative way to qualify for the program’s reward. This take FMLA leave within five business days, absent notice must be included in all plan materials that describe extenuating circumstances. The DOL has a model the terms of the wellness program. eligibility notice (Form WH-381) that employers may use.

Americans with Disabilities Act (ADA) OSHA Severe Injury Reporting Wellness Notice Report severe workplace injuries and illnesses to OSHA. The ADA imposes nondiscrimination requirements on Work-related employee fatalities must be reported within certain wellness plan designs. To comply with the ADA, eight hours, and any in-patient hospitalization, amputation wellness plans that collect health information or involve or loss of an eye must be reported within 24 hours. medical exams must provide a notice to employees that explains how the information will be used, collected and HIPAA Breach Notification kept confidential. Employees must receive this notice If your health plan has a breach of unsecured protected before providing any health information and have enough health information (PHI), notify each individual whose time to decide whether to participate in the program. unsecured PHI has been accessed, acquired, used or disclosed as a result of the breach. The notice must be Form I-9 Verification provided without unreasonable delay and in no case later Verify the identity and employment authorization of each than 60 calendar days after the breach is discovered. new hire by completing and retaining Form I-9. To improve Notification must also be provided to HHS and, in some onboarding efficiency, you can ask newly hired employees cases, to the media. to review the form and instructions and bring their identity and employability documents with them on their first day. IRS Form 8928 (Excise Taxes for Group Health Plan Violations) ACA Exchange Notice File Form 8928 with the IRS by the due date of your Provide all new hires with a written notice about the corporate tax return if your company owes an excise tax availability of the Exchanges. The DOL has model notices for a group health plan violation. The excise tax may be for employers to use. triggered due to certain violations of the ACA, COBRA, HIPAA and the Mental Health Parity and Addiction Equity Act. The excise tax for group health plan violations is generally $100 per day per individual per violation, subject to certain minimum and maximum amounts.