The Compliance Download, April Vol. 2

Midyear Compliance: Key Disclosure Deadlines for Group Health Plans

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Now is the time for health plan sponsors to review key federal compliance obligations that occur midyear. These deadlines help ensure plan participants receive required disclosures and reduce the risk of penalties.

Key Compliance Dates (Calendar‑Year Plans)

June 1, 2026

• Prescription Drug Data Collection (RxDC) Reporting: Group health plans and issuers must annually submit prescription drug and health care spending data to the Centers for Medicare and Medicaid Services. This reporting process is referred to as the RxDC report. Most health plan sponsors will rely on third parties, such as issuers, third-party administrators or pharmacy benefit managers, to prepare and submit the RxDC report for their health plans.

July 31, 2026

• Form 5500 (if required): For applicable calendar-year plans, the normal filing deadline is July 31. Health plan sponsors may request a one-time extension of 2.5 months by filing IRS Form 5558 by the normal due date of the Form 5500.
• PCORI Fees (Self‑Insured Plans Only): Health plan sponsors with self-insured plans must pay a fee to fund the Patient Centered Outcomes Research Institute (PCORI). If a plan is fully insured then this fee is paid by the carrier on behalf of the sponsor. Sponsors must file IRS Form 720 to report and pay PCORI fees each year, no later than July 31 of the year following the last day of the plan year.

Best Practices for Accommodating Mental Health Conditions in the Workplace

Mental health is an important part of a healthy, productive workplace. Under the Americans with Disabilities Act (ADA), employers with 15 or more employees are required to provide reasonable accommodations to qualified individuals with disabilities, including certain mental health conditions, unless doing so would create an undue hardship.

This topic is especially important as mental health awareness—and related accommodation requests—continue to rise. Failure to comply can result in EEOC charges, costly litigation, and reputational harm.

Employers should take proactive steps to ensure compliance. Key actions include implementing clear, inclusive accommodation policies; recognizing when an employee may need support; and engaging in a timely, individualized interactive process. Employers should also request only necessary medical documentation, maintain strict confidentiality, and consider flexible, practical accommodations such as schedule adjustments, remote work, or modified job duties. Training managers and HR staff to handle requests sensitively and consistently is also critical.

By adopting these best practices, employers can reduce legal risk while fostering a more inclusive, supportive workplace.