Reporting and Filing

Plan Type: Self-Insured Plans

Notice/Disclosure: Medicare Creditable Coverage Filing

Requirements: From Bywater to Employer: October 7, or upon request

From Employer to CMS: 60 days from beginning of Plan Year, 30 days after Termination of Rx Plan, or 30 days after change in coverage status

Responsibility: Bywater/Employer

Notice/Disclosure: Form 5500 Filing

Requirements: Schedule A – Insurance Information

Schedule A must be completed if any benefits under an employee benefit plan are provided by an insurance company, insurance servicer, or other similar organization. This includes investment contracts with insurance companies. Insurance premiums, broker commissions and year-end enrollment information are reported on Schedule A. Self-insured plans are required to attach Schedule A for stop-loss coverage ONLY IF the plan itself is the named policyholder of the stop-loss policy. Typically, a plan is the policyholder of a stop-loss policy only when it is funded through a trust. Schedule A must be attached to Form 5500 and has the same due date as the Form 5500.

Unfunded plans with fewer than 100 employee participants do not need to file a Form 5500.

Data from Bywater to Employer: End of 6th month after Plan Year Ends

From Employer to Government: End of 7th month after Plan Year Ends

Responsibility: Bywater/Employer

Notice/Disclosure: 1094/1095 C & B Filing

Requirements: An Applicable Large Employer (ALE) must use Forms 1094-C and 1095-C to report the information required under sections 6055 and 6056 about offers of health coverage and enrollment in health coverage for their employees. Generally, employers with 50 or more full-time employees (including full-time equivalent employees) in the preceding calendar year are considered an ALE.

Small employers that are not ALEs and sponsor self-insured group health plans will use Forms 1094-B and 1095-B to report information about covered individuals.

Bywater to Employer: January 15
Employer to Employees: January 31

Responsibility: Bywater/Employer

Notice/Disclosure: PCORI

Requirements: The PCORI fee is reported once a year (by July 31) on the second quarter Form 720, and is paid using the Electronic Federal Tax Systems (EFTPS).

Data from Bywater to Group: June 30th of the year following the end of the Plan Year

Responsibility: Bywater/Employer

Notice/Disclosure: DCR

Requirements: The CAA requires group health plans and health insurers to report detailed data about prescription drug pricing and healthcare spending.

For calendar year 2022 and all subsequent years, reporting is due annually by June 1st following the close of the calendar year.

Responsibility: Employer – Bywater will complete for fee

Notice/Disclosure: MHPAEA

Requirements: The Department of Labor (DOL) is actively auditing plans for Mental Health Parity compliance.  Plans may need up to 21 different NQTL Comparative Analysis documents on hand to demonstrate during an audit that cost sharing and treatment limits on mental health or substance abuse services are no more restrictive than those for medical or surgical care. 

Responsibility: Employer – Bywater will complete for fee

Notice/Disclosure: Gag Clause Attestation

Requirements: Confirms that the plan has not, since December 27, 2020, entered into any agreement with a provider, network of providers, TPA, or any other service provider offering access to a network or association of providers that contains any prohibited gag clause. Must be made through HIOS by December 31.

Responsibility:  Employer – Bywater will complete with signed election form

Plan Type: Plans that file a 5500

Notice/Disclosure: Summary Annual Report

Requirements: Same data for the 5500

The plan must provide to employee participants a narrative summary of the financial information contained on the Form 5500.

Electronic Distribution: Email and other Internet-based methods that comply with the DOL safe harbor can be used.

Distribution Requirement: Distribute to employees participating in the plan within 9 months of the close of the plan year or 2 months after the due date for filing the Form 5500.

Responsibility: Employer

Plan Type: Self-Insured Plans

State: ID


  • Immunization Survey – March 1
  • Health Survey – May 1

Both completed by Bywater

Responsibility: Bywater

Plan Type: Self-Insured Plans with CT Members

State: CT

Requirements: Pediatric Vaccination Program – Bywater accounting bills the Employer

Responsibility: Bywater Bills, Employer Pays

Plan Type: Self-Insured Plans with MA Provider Claims

State: MA

Requirements: MA Surcharge – Bywater claims bills Employer

Responsibility: Bywater Bills, Employer Pays

Plan Type: Self-Insured Plans with NY Provider Claims

State: NY

Requirements: HCRA – Bywater claims bills Employer

Responsibility: Bywater Bills, Employer Pays

Plan Type: Self-Insured Plans w WA residents

State: WA

Requirements: WVA – Pursuant to RCW 70.290.075, if the clients represented by the TPA offer private health plan or self-funded employer plan coverage that might include vaccine material being provided to patients under the age of 19, then both state-based and out-of-state TPAs are required to register with the Washington Vaccine Association so we can keep you informed of the latest policies, changes, and reductions to vaccine charges.

WAPAL – Employers that provide coverage to Washington residents through a self-insured or level funded plan will be required to pay a quarterly WAPAL assessment. Employers must complete the reporting through the WAPAL Fund Online Assessment System. Due within 45 days of the end of each quarter.


WVA – Bywater

WAPAL – Employer