The importance of Q2
The second quarter typically has fewer fixed federal deadlines for calendar-year group health plans. It’s a good time to review processes, meet ongoing requirements, and prepare for Q3 and Q4 filings and notices.
The following calendar provides general information to support your compliance efforts. It is not comprehensive. Requirements can vary by plan design, plan year, and funding arrangement. Work with your benefits adviser and legal counsel to identify specific plan needs.
April 2026
Use this time to review processes related to ongoing plan responsibilities and Employee Retirement Income Security Act (ERISA) requirements. Examples include:
- Children’s Health Insurance Program Reauthorization Act (CHIPRA) notices
- Consolidated Omnibus Budget Reconciliation Act (COBRA) notices: Election, qualifying events,continuation coverage rights, early termination, insufficient payment, etc.
- Health Insurance Portability and Accountability Act (HIPAA) notices: Special enrollment rights, privacypractices, breach notification, etc.
- Mental Health Parity and Addiction Equity Act (MHPAEA) notices: Medically necessary determinationcriteria, claims denial, increased cost exemption, etc.
- Newborns’ and Mothers’ Health Protection Act Notice
- No Surprises Act disclosures
- Women’s Health and Cancer Rights Act (WHCRA) notices
Ensure that notices are up to date and distributed promptly when a triggering event occurs. Document your procedures and retention practices. These actions aren’t tied to a specific calendar date, but they are vital to maintaining plan compliance.
May 2026
May is a good month to review ongoing plan governance. These efforts protect plan participants, strengthen fiduciary oversight, and allow for corrective actions to be taken before open enrollment and year-end deadlines.
- Work with vendors to ensure ongoing compliance. In particular, review transparency in coverage and Consolidated Appropriations Act requirements to improve benefits transparency and participant protection. Verify that the required price comparison tool is functional. Update machine-readable files. Prepare for the annual Gag Clause Prohibition Compliance Attestation, due at the end of the calendar year.
- Review plan documentation and notices. Ensure that plans include an up-to-date Summary Plan Description, Summary of Benefits and Coverage, and Summary of Material Modifications. Check that they have been distributed on time and in accordance with required schedules. Verify that notices are sent for triggering events related to COBRA, HIPAA, CHIPRA, WHCRA and other legislative requirements.
- Examine claims and appeals procedures. Confirm that ERISA notices and timelines are being followed. Review adverse benefit determination letters for clarity and compliance.
- Assess HIPAA privacy and security. Review business associate agreements to ensure proper handling of protected health information. Ask vendors for evidence of security audits and breach response protocols.
- Consider eligibility audits. Verifying benefits and dependent eligibility can reduce risks and costs for current and future plan years.
- Document vendor performance. Review costs, services, and return on investment. Ensure that fees and solutions meet fiduciary obligations.
- Prepare for open enrollment. Discuss potential plan design changes, draft updates to plan documents, and confirm timelines with carriers and third-party administrators.
June 2026
June can help you build momentum toward significant Q3 deadlines. Laying the groundwork now helps avoid last-minute issues and potential penalties.
June 1: Submit the Prescription Drug Data Collection (RxDC) report to the Centers for Medicare and Medicaid Services. This report includes prior-year data on drug spending, rebates, and premiums for calendar-year plans. The Horton Group insurance company recommends working with vendors before this date to ensure complete and accurate submissions.
Prepare for July 31 deadlines: Two important deadlines fall at the end of July:
- Form 5500 filing for calendar-year plans
- Patient-Centered Outcomes Research Institute (PCORI) fee payment for self-funded plans
Use the remaining time in June to gather claims data, review plan financials, and coordinate responsibilities with vendors.
Review, coordinate and prepare
Q2 is less about fixed deadlines and more about plan processes and governance. By using this quarter to review notices, coordinate with vendors, and prepare for July filings, your organization can stay ahead of compliance obligations and reduce avoidable risks.
For more information, contact your insurance broker or benefits adviser. They can help you review deadlines and best practices to ensure compliance for your plan needs.
Note: This resource provides general information to support your compliance efforts. This information is not comprehensive and should not be considered legal advice. Requirements can vary by plan design, plan year, and funding arrangement. Work with your benefits adviser and legal counsel to identify specific plan needs.
For support on this or other employee benefits topics, connect with OneGroup’s Employee Benefits Team.
This content is for informational purposes only, should not be considered professional, financial, medical or legal advice,and no representations or warranties are made regarding its accuracy, timeliness or currency. With all information, consultwith appropriate licensed professionals to determine if implementing any recommendations would be in accordance withapplicable laws and regulations or to obtain advice with respect to any particular issue or problem.
Copyright © 2026 Applied Systems, Inc. All rights reserved.