As important compliance dates approach, employers and plan sponsors should be aware of several upcoming deadlines and regulatory changes that may affect their employee benefit plans.
October 15, 2025 – Form 5500 Filing Deadline
For calendar year employee benefit plans, if a Form 5558 extension was timely filed, the deadline to submit Form 5500 has been extended from July 31, 2025, to October 15, 2025.
October 15, 2025 – Prescription Drug Coverage Notices
Employers offering group health plans with prescription drug coverage must provide notices to participants who are enrolled in Medicare Part A or Part B. These notices inform participants whether the plan’s prescription drug coverage is considered creditable or non-creditable. Your third-party administrator should be able to provide this information, which is essential for Medicare-eligible participants deciding whether to enroll in Medicare prescription drug coverage.
January 1, 2026 – Catch-Up Contribution Changes Under SECURE 2.0
The IRS has issued final regulations implementing provisions of the SECURE 2.0 Act of 2022:
- Starting in 2026, employees earning more than $145,000 in the prior year who make catch-up contributions to 401(k), 403(b), or 457(b) plans must designate those contributions as Roth contributions.
- SECURE 2.0 also increased catch-up contribution limits for employees ages 60–63, effective January 1, 2025. The final regulations provide guidance on how these changes should be applied.
Employers maintaining retirement plans may have questions about implementing these new requirements, particularly if their plans do not currently allow for Roth contributions. Our ERISA attorneys can help employers navigate these changes and ensure compliance.
ERISA Case Update – Cigna “Ghost Network” Class Action
In Hecht v. Cigna Health and Life Insurance Co., Case No. 1:24-cv-05926 (N.D. Ill.), a class action lawsuit alleges that Cigna breached its ERISA fiduciary duties by maintaining a “ghost network” of providers. Participants claim that unclear information about in-network status led them to receive services from out-of-network providers, resulting in higher costs.
This case highlights the importance for plan sponsors to regularly review and audit provider contracts, claims handling, and participant communications to ensure accuracy and reduce fiduciary risk.
How Frier Levitt Can Help
Frier Levitt’s ERISA attorneys are available to assist employers and plan sponsors in understanding and applying these requirements.
Contact us for guidance.
