Mid-Year Employee Benefit Plan Compliance Checklist: What to Focus on Before Year-End

Article | July 10, 2025

Authored by Your Firm LLC

Mid-Year Benefit Plan Checkup: Stop Compliance Curveballs Before They Strike

Nearly 60 percent of recent Department of Labor (DOL) penalty letters cite late or missing Form 5500 filings. That sobering statistic is a reminder that waiting until year-end is risky and expensive—civil penalties now reach up to $2,670 per day. A concise mid-year audit gives plan sponsors the breathing room to correct issues long before regulators or auditors come calling.

Three Critical Reviews Before Summer Ends

• Plan Documentation & Reporting. Make sure every welfare and retirement plan has an up-to-date SPD or wrap document that reflects newer benefits such as virtual care or lifestyle stipends. Calendar-year plans must file Form 5500 by July 31 (or October 15 with a timely Form 5558 extension). “Treat your wrap document like living code—if it’s not updated, you’re already out of compliance,” cautions Thomas Healy, CPA, QKA, Partner-in-Charge of MBN’s Employee Benefit Plan practice.
• Payroll Reconciliation. Compare year-to-date wages, elective deferrals, and employer matches against provider records. A $50 mistake one pay period becomes a four-digit variance by December. Use your recordkeeper’s mid-year contribution report or export data to Excel for a line-by-line cross-check.
• Regulatory Shifts on the Horizon. The Inflation Reduction Act caps Medicare Part D out-of-pocket costs at $2,000 starting in 2025. Meanwhile, the Consolidated Appropriations Act (CAA) expands mental-health-parity testing and requires a documented NQTL analysis on demand. “Sponsors who start the NQTL review now will avoid a paperwork scramble during open enrollment,” notes Lynn Eller, CPA, Director of Tax Strategy.

Proactive Best Practices

Run nondiscrimination tests on Section 125 cafeteria plans mid-year, not after year-end. Verify COBRA notices and HIPAA BAAs following any headcount reduction or M&A activity. Use this window to train staff on amended payroll processes and align vendor data feeds—mid-year is the sweet spot for realignment.

How MBN & Company LLP Moves You Forward

Our Employee Benefit Services group delivers a two-week “rapid review” that pinpoints documentation gaps, validates payroll feeds, and maps upcoming regulatory impacts. Clients leave with an actionable roadmap and the confidence that their plans—and their people—are protected.

Ready to de-risk year-end? Email ebp@mbnco.com or call 800-555-MBN1 to schedule your mid-year compliance checkup. Let MBN & Company help move you forward before compliance curveballs even leave the pitcher’s hand.