Protecting Your Assets

APRIL 23, 2020  |  1 MIN READ

Some Benefit Reporting Due Dates Extended


The IRS and Department of Labor have extended some deadlines due to COVID-19.
Find out which extensions will have the biggest effect on your employee benefits business operations.

Some Benefit Reporting Due Dates Extended
With the declaration of a public emergency, various agencies will typically provide employers automatic extensions of specific reporting due dates.
  • From a federal perspective, the IRS announced in Notice 20-23 that certain government reports due between April 1, 2020 and July 14, 2020 are automatically extended to not be due until July 15, 2020.
  • Page 6 of that notice says the reporting requirements that can be automatically extended during the national emergency are listed in Revenue Procedure 18-58, which includes Form 5500. The DOL would also honor such automatic extensions for 5500 filings of welfare benefit plans. See PDF pages 57-58 of that revenue procedure for these details.
  • Therefore, plan years that ended in September, October, or November of 2019, as well as any plans that had filed for an extension which moved the due date to fall within the April 1 to July 14 window, are all automatically extended to now have Form 5500 due July 15, 2020.
  • This means calendar year plans are not being granted an automatic extension at this time. These plans will either have to file by the normal July 31, 2020 deadline or submit a request for extension using Form 5558.
Consistent with San Francisco’s Emergency Proclamationthe City is cancelling (rather than delaying) the employer requirement to submit the 2019 Annual Reporting Form for the Health Care Security Ordinance and the Fair Chance Ordinance. 
  • This only means that the 2019 Annual Reporting Form does not need to be submitted to OLSE.
  • Employers must continue to make health care expenditures on behalf of their Covered Employees by making City Option payments and/or paying for health insurance.

This material is for general information only and should not be considered as a substitute for legal, medical, 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.