2024-01-29 DOL Updates Civil Monetary Penalties for 2024

The Department of Labor has announced updated penalty amounts for violations assessed a penalty after January 15, 2024.  Below is a table of some of the civil monetary penalties relevant to employee benefit plans.  The DOL can waive penalties or assess lower penalties than these when they determine the employer has acted in good faith to promptly identify and correct errors it discovers.  We’ll use some acronyms in the table, but you can certainly reach out to your IMA Benefits team if you would like to discuss any of these.

Requirement	2023 Penalty	2024 Penalty
Filing Form 5500	$2,586 per day it’s late	$2,670 per day it’s late
Furnishing SBCs	$1,362 per failure	$1,406 per failure
GINA violations	$137 per person per day	$141 per person per day
Medicaid/CHIP notice	$137 per person per day	$141 per person per day
MEWA M-1 Filing	$1,881 per day it’s late	$1,942 per day it’s late

IMA will continue to monitor regulator guidance and offer meaningful, practical, timely information. This material should not be considered as a substitute for legal, tax and/or actuarial advice. Contact the appropriate professional counsel for such matters. These materials are not exhaustive and are subject to possible changes in applicable laws, rules, and regulations and their interpretations.