Annual Benefits Administration Checklist
Plan Renewal Review
Request the loss-ratio report and large-claimant summary for medical and dental from the broker. Keep the file — it's the basis for the renewal negotiation and any stop-loss conversation. For groups under 50 the carrier may withhold claims data; ask anyway.
Use Mercer, Kaiser Family Foundation, or NALA salary-and-benefits surveys filtered to firms of similar size and region. Law firms in the 10-50 attorney band typically run higher-than-average premiums because of older partner demographics — adjust expectations accordingly.
Walk the investment policy statement with the recordkeeper or 3(38) advisor. Flag any fund on watch for two consecutive quarters. Document the review in writing — fiduciary safe harbor under ERISA 404(c) requires a contemporaneous record.
Capture the medical, dental, vision, life, and disability renewal increases from the broker's renewal letter. Anything over a 10% medical increase should trigger a re-shop — that's the threshold most managing partners will fund a marketing exercise for.
Compliance and Legal Review
The 2025 affordability threshold is 9.02% of household income — usually proxied by the rate-of-pay or W-2 safe harbor. Recalculate the lowest-cost employee-only premium against the lowest-paid full-time staffer (often a receptionist or records clerk). If it fails, the firm owes the Section 4980H(b) penalty per affected employee.
Law firms fail NDT routinely — equity partners are HCEs and their deferral rates skew the ADP/ACP test. Run mid-year so you have time to refund excess deferrals or do a corrective contribution before year-end. Top-heavy testing matters too: if key employees hold more than 60% of plan assets the firm owes a 3% non-elective.
SBCs must be distributed at least 60 days before any mid-year material change and at open enrollment. SPDs need refreshing whenever plan terms change and at minimum every 5 years (every 10 if no amendments). Distribute electronically only to employees who meet the DOL e-disclosure safe harbor — partners and associates qualify; non-attorney staff often do not.
Broker and Carrier Management
Issue an RFP through the broker to at least three competing carriers. Provide a redacted census, claims experience, and current plan design. Allow four weeks for firm quotes — anything tighter and carriers will decline to quote.
Ancillary lines are easier to push back on than medical. Use multi-year rate guarantees as leverage; carriers will trade a 0% renewal for a two-year lock. Confirm the broker's commission structure in writing — Schedule C of Form 5500 will eventually require it disclosed.
Pin down ID-card delivery, claim turnaround, and member-services hours in the renewal contract. If the firm is on a level-funded or self-insured arrangement, verify the stop-loss specific and aggregate attachment points and the laser list.
Open Enrollment Setup
Build the new plan year inside Gusto, BambooHR, Paylocity, or whichever HRIS the firm runs. Verify EDI feeds to each carrier are updated for the new plan codes. Test with a dummy enrollment before opening to staff — broken EDI feeds in week one of the plan year produce ID-card chaos.
Side-by-side comparison of the medical plans, contribution amounts at each tier, HSA vs. FSA decision tree, and a one-page "what's changing" summary up front. Partners will skim; legal assistants will read every word — write for both audiences.
Set a hard close. Two-week window is standard for firms under 50; three weeks if you have multiple offices. After close, only qualifying life events open the system — make sure the mid-year QLE workflow is documented before the window closes.
Employee Communication and Enrollment
Lead with the enrollment dates and the deadline. Attach the benefits guide and the SBCs (legally required at OE). Copy the managing partner so it carries weight — staff ignore HR-only emails about benefits.
Bring the broker. Run two sessions — one in person at the main office, one over Zoom for remote and satellite-office staff. Record the Zoom for the people who can't attend live.
Send mid-window and 48-hour reminders. Track non-electors and confirm whether the firm's default is current-year-rollover or no-coverage — partners frequently miss deadlines and complain in January when their HSA contribution didn't roll over.
Post-Enrollment and Year-End Filings
First-month-of-plan-year invoices are routinely wrong — terminations not processed, dependents miscategorized, COBRA enrollees still on the active bill. Match line by line against the HRIS roster and dispute discrepancies within 30 days; carriers refuse retroactive credits beyond that.
Refunds of excess deferrals must go out by March 15 to avoid the 10% excise tax under IRC 4979. Coordinate with the recordkeeper to issue the 1099-Rs. For top-heavy plans, fund the 3% non-elective through a separate payroll batch.
Applicable Large Employers (50+ FTEs) owe 1095-C to each full-time employee by March 3 and to the IRS by March 31 (electronic). Smaller firms providing self-insured coverage owe 1095-B. Get this off the bookkeeper's plate before tax season — the penalty is per form per failure.
Due July 31 for calendar-year plans (or October 15 with a Form 5558 extension). Plans with under 100 participants file the 5500-SF; larger plans file the full 5500 with Schedule C disclosing service-provider compensation. Confirm the ERISA fidelity bond covers at least 10% of plan assets up to $500,000 ($1M for plans holding employer securities).
