ALERT / MARCH 16, 2026

Upcoming key compliance deadlines & reminders for second quarter 2026

7 MIN READ

The second quarter of 2026 brings a few employee benefits compliance deadlines that plan sponsors should note and prepare for in advance. This alert highlights key filing, notice, contribution, and reporting obligations commonly applicable during the April-June timeframe, including ERISA plan filings, health plan reporting, and HSA-related actions.

While not every deadline applies to all employers, proactive review of these obligations can help ensure timely compliance and reduce the risk of penalties. Employers should coordinate with internal teams and third-party administrators as needed to confirm responsibilities and submission processes.

We have separated our reminders into two categories: standard federal deadlines and select state and local deadlines. Within each category, we follow our typical chronological approach. Deadlines may or may not be applicable to your group, depending on the employer and plan characteristics.

Here are potential action items for the second calendar quarter of 2026:

STANDARD FEDERAL DEADLINES

April 14 - Distribute reminder to participants regarding availability of HIPAA privacy notice (Recommended action)

This obligation applies to sponsors of ERISA and non-ERISA health plans, where the plan is self-insured or insured but the sponsor is “hands on” regarding the plan’s protected health information.

This reminder is due every third year. Most plan sponsors with HIPAA privacy and security obligations moot the reminder duty by supplying a HIPAA privacy notice regularly (e.g., as part of initial and open enrollment packets).

This notice may be provided electronically in accordance with specific requirements. See our publication, Electronic Distribution of Welfare Benefit Plan Required Documents (opens a new window).

April 15 - Make final HSA contributions toward 2025 HSA limits and/or make HSA corrections related to 2025 calendar year

Applies to employers who provide HSA enrollment. Employers and individuals have until the individual's tax filing deadline to make HSA contributions and corrections related to the tax filing year.

April 30, May 31 and June 30 - File Form 5500 for plan years ending Sept. 30, Oct. 31 and Nov. 30, 2024, respectively (Due on the last day of the 7th month after end of the plan year)

ERISA plans must file a Form 5500 at least annually unless the plan is exempted from the filing requirement. Filing is accomplished electronically through the Department of Labor’s (DOL) EFAST (opens a new window) portal.

Form 5500 extensions are available by filing a Form 5558 (opens a new window) with the DOL on or before the filing’s initial due date. Filing Form 5558 allows the plan up to an additional 2¹/₂ months to complete the filing.

June 1 - Submit prescription/medical plan cost reporting to CMS (RxDC)

Applies to all employers. The Consolidated Appropriations Act requires group medical plans to file a report with CMS reflecting a variety of costs and other medical data with respect to the group health plans’ prescription drug and other benefits. Does not apply to excepted benefits.

The filing is completed electronically through the CMS Enterprise Portal (opens a new window). If the employer plan sponsor is filing any part of the filing, the employer will need to establish an HIOS account. However, most third-party administrators and/or pharmacy benefit managers contracted to provide services to the group health plan will assist and/or submit filings on behalf of the group health plan.

STATE AND LOCAL DEADLINES

April 1 - Managed Care Organization Payor Assessment (Submit monthly assessment fee for services rendered in Massachusetts.)

The Massachusetts Managed Care Organization (MCO) Payor Assessment applies to managed care organizations, including carriers and self-funded plans with Massachusetts members.

April 1 - New Mexico Vaccine Purchasing Act (Submit quarterly covered lives assessment payment.)

The New Mexico Vaccine Purchasing Act (VPA) applies to fully insured plans and self-insured ERISA plans (including TPAs) covering children under age 19 who reside in New Mexico.

April 25 - Vermont Health Care Fund Contribution Assessment (Submit quarterly reporting and assessment payment for previous quarter.)

The HCFCA is a quarterly employer assessment designed to support Vermont’s healthcare programs. Employers with five or more full-time equivalent (FTE) employees in Vermont who do not offer health coverage to all employees may owe this assessment.

April 30 - District of Columbia individual mandate reporting (Submit forms 1095-C and/or 1095-B with Form 1094-C or 1094-B to Washington, D.C. Office of Tax and Revenue.)

Applies to employers who provided medical coverage to District of Columbia residents in the prior calendar year.

April 30 - San Francisco Health Care Security Ordinance (All plans subject to HCSO must file annual report form for prior calendar year.)

Applies to all employers subject to the San Francisco Healthcare Security Ordinance.

April 30 - San Francisco Health Care Security Ordinance (Fully insured plans to make HCSO contributions for any Q1 expenditure shortfalls.)

Applies to fully insured employers subject to the San Francisco Healthcare Security Ordinance.

April 30 - Michigan Insurance Provider Assessment Act (Pay quarterly assessment based on annual notice.)

Health insurers and certain managed care plans must pay quarterly assessments based on prior-year member months.

April 30 - Rhode Island Vaccine Assessment Program (Submit quarterly covered lives report and assessment payment for previous quarter.)

The Rhode Island Vaccine Assessment Program (RIVAP) requires certain health plans and payers to fund the state’s universal vaccine purchasing program through quarterly assessments based on covered lives.

April 30 - Washington Cares tax (File report and remit payment of payroll tax withholdings from Q1 for Washington workers.)

Applies to fully insured and self-insured ERISA plans. Employers collect premiums from employees via after-tax payroll withholdings to support WA Cares long-term care insurance program.

May 1 - Managed Care Organization Payor Assessment (Pay monthly assessment fee for services rendered in Massachusetts.)

The Massachusetts Managed Care Organization (MCO) Payor Assessment applies to managed care organizations, including carriers and self-funded plans with Massachusetts members.

May 15 - Alaska Vaccine Assessment Program (Report covered lives and related data for Q1 via the AVAP reporting system.)

Employers and other assessable entities (health insurers, TPAs, self-funded ERISA plans) must report covered lives and vaccine usage data to the Alaska Vaccine Assessment Program (AVAP).

May 15 - Maine Vaccine Board (Submit Maine Vaccine Board quarterly reporting and payment for previous quarter covered lives assessment.)

Employers and health plans subject to Maine’s Vaccine Board childhood immunization assessment (health insurers, TPAs, self-funded employers) must report covered lives quarterly.

May 15 - New Hampshire Vaccine Association (File quarterly reporting and pay quarterly childhood vaccine assessment fees.)

Health insurers, TPAs, and other assessable entities must report covered lives under age 19 and pay quarterly assessments.

May 15 - New Hampshire Health Plan (Report covered lives and pay assessment fees.)

The New Hampshire Health Plan (NHHP) Assessment funds key state health initiatives. Health carriers, TPAs, and other assessable entities must report covered lives and pay quarterly assessments.

May 15 - Vermont Vaccine Purchasing Program (Submit reporting and assessment payment for previous quarter.)

The Vermont Vaccine Purchasing Program (VVPP) is Vermont’s universal vaccine program. It applies to health insurers, self-insured employers, TPAs, HMOs, and other entities that cover Vermont lives.

May 15 - WAPAL Fund (Submit WAPAL Fund covered lives report and pay quarterly assessment.)

Applies to all assessed entities with covered lives in Washington, including Washington employers and out-of-state employers with covered lives in Washington. Applies to fully insured and self-insured ERISA plans.

June 1 - Managed Care Organization Payor Assessment (Pay monthly assessment fee for services rendered in Massachusetts.)

The Massachusetts Managed Care Organization (MCO) Payor Assessment applies to managed care organizations, including carriers and self-funded plans with Massachusetts members.

June 15 - Idaho Vaccine Assessment Program (Pay annual assessment fee due based on covered lives reporting.)

Applies to fully insured and self-insured ERISA plans (via carriers, TPAs, and plan sponsors operating in Idaho).

Not legal advice: Nothing in this alert should be construed as legal advice. Lockton may not be considered your legal counsel, and communications with Lockton's Compliance Consulting group are not privileged under the attorney-client privilege.