Human Resources Compliance Calendar Washington and Lee University Annual Calendar of Significant Reporting Compliance Activities

Human Resources

IPEDS Winter Collection Ends1

Effective Period of Withholding Exemption Certificate2

SAR (Health/Welfare Plans)3

Employer CHIP Notice for Health and Dental Plans4

No action items

No action items


  • ERISA: Form 55005
  • ACA: PCOR Fee Reporting and Payment6

No action items


  • IPEDS Fall Collection Starts7
  • Drug-Free Schools and Communities Act: Annual Distribution8
  • SAR (Retirement Plan)3


  • Campus Security Act: Annual Security Report9
  • Campus Sex Crimes Prevention Act10
  • WHCRA Notice11
  • Notice for Creditable Coverage12
  • IPEDS Fall Collection Ends7

No action items


  • IPEDS Winter Collection Starts7
  • U.S. Tax Code: Withholding Exemption Certificates13
  • Drug-Free Schools and Communities Act: Biennial Review14


  • Virginia Bi-Weekly Reporting of New Hires15

1Program Participation Agreements and IPEDS
The Winter collection includes the Employees by Assigned Position component to classify all institutional staff, as well as the Faculty Salaries and the Fall Staff components of IPEDS. In addition, institutions have the opportunity to provide Enrollment data at this time. Institutions will be able to lock the Enrollment Component in the Winter or Spring. The Fall Staff component is provided for convenience, but data are NOT required this year. The Winter collection opens in December and closes in January. See for exact dates.

2Effective Period of Withholding Exemption Certificate
A Form W-4 filed by an employee expires on February 15th of the year following the year in which the Form W-4 was given to employer. The employer must now begin withholding for any employee who previously claimed an exemption, but has not given the employer a new Form W-4 for the current year. If the employee does not give the employer a new Form W-4 (see December), withhold tax as if the employee is single, with zero withholding allowances. See the Internal Revenue Service Calendar.

3Summary Annual Report (SAR): Retirement Plan and Health/Welfare Plan
A summary annual report must be sent to each plan participant and beneficiary receiving benefits within nine months of the end of the plan year. If the institution obtains an extension for filing the 5500, the extension for distributing is extended to two months after the filing of the form 5500. See TIAA-CREF Important Dates for ERISA Reporting.

4Employer CHIP Notice for Health and Dental Plans (Children's Health Insurance Program Reauthorization Act of 2009)
Notice of premium assistance subsidy to employees residing in states that have such programs. Notice must include contact information of state agencies responsible for premium assistance subsidy in states where employees live (not where employer is located).

Deadline is first day of plan year each year – July 1 for W&L plans, but HR plans to include this in open enrollment packets each April. Notice may be distributed hard copy or by email to those who regularly use computers in their jobs for the employer.

5Employee Retirement and Income Security Act (ERISA)
The administrator of an employee benefit plan must file a form 5500 within 210 days after the close of the plan year. Thus, if the plan year is the same as the calendar year, and ends Dec. 31, then the filing deadline is July 31 of the next year. An extension of the filing deadline of up to two-and-a-half months can be obtained by using form 5558. If the plan year and tax year are the same, and you obtain an extension for filing the institution's tax return, then the deadline for the 5500 is automatically extended as well. See TIAA-CREF Important Dates for ERISA Reporting.

6Affordable Care Act: PCOR Fee Reporting and Payment
By July 31 of each year between 2013 and 2019 (for plan years ending on or after 10/1/12 and before 10/1/19), the university must file IRS Form 720 and pay applicable PCOR (Patient Centered Outcome Research Institute) fees for any covered self-insured plans, at the applicable rate ($1.00 per covered life for 2012, $2.00 for 2013, adjusted for health inflation thereafter).

7Program Participation Agreements and IPEDS
The Fall collection for IPEDS (Institutional Characteristics and Completions) opens in September and closes in October. Reporting is done online. See for exact dates for submission of data on tuition and completion (the Fall Collection). This is the first of three annual data collection periods. Designated institutional personnel should have received new 2006-07 User IDs and passwords (if not, contact the Helpdesk). Click here for information, schedules, and links to survey instruments.

8The Drug-Free Schools and Communities Amendments of 1989: Annual Distribution
Annual distribution to employees of the institution's standards of conduct with respect to illegal drugs and alcohol, a description of the applicable legal sanctions and health risks; as well as availability of drug and alcohol counseling available to employees. Must also include a statement on sanctions the institution will impose for violation of the standards of conduct. The distribution method must be one that ensures that the information will reach every faculty and staff employee and is suggested to occur concurrent with beginning of academic year.

9Campus Security Act of 1990
The Campus Security Act requires colleges to report campus crime statistics and security measures to all students and employees by October 1 of each year. The report can be provided through publications, mailings, or electronic media sent directly to individuals. If it is posted to a website, notice must be sent through U.S. mail, campus mail, or directly to the email address of all enrolled students and current employees. [The notice must include the following: 1) identification of the information required to be disclosed, 2) the exact electronic web site address, 3) a statement that the individual is entitled to a paper copy, upon request, and 4) information as to how the individual can request a paper copy.]

Information noting the availability of the campus security report, including an opportunity to request a copy, must be included in appropriate publications, mailings, and/or electronic communications to prospective students. Information regarding the availability of this report must be made to prospective employees. The annual security report must also be submitted to the Secretary of Education (over the internet) each year, by Oct. 15th of each year.

10Campus Sex Crimes Prevention Act
This law requires a statement advising the campus community where law enforcement agency information provided by a State concerning registered sex offenders may be obtained, such as the law enforcement office of the institution, a local law enforcement agency with jurisdiction for the campus, or a computer network address. Notification may be accomplished by adding the statement to the Annual Security Report required by the Campus Security Act. Suggested deadline of Oct. 1 of each year to coincide with Annual Security Report.

11Women's Health and Cancer Rights Act Notice
Written notice of the availability of coverage for breast reconstruction in connection with a mastectomy must be delivered to the health plan participants upon enrollment and annually thereafter (suggested to coincide with Notice for Creditable Coverage, which currently occurs annually in October).

12Notice for Creditable Coverage
The university must disclose to all Part D eligible individuals enrolled in or seeking to enroll in the coverage whether the coverage is creditable prescription drug coverage prior to the commencement of the Annual Coordinated Election Period that begins on November 15 of each year. (Note: this disclosure currently occurs in October).

13U.S. Tax Code: Withholding Exemption Certificates
The employer is required to request a withholding exemption certificate from each employee, but if the employee fails to furnish such certificate, the employer shall consider that employee a single person claiming no withholding. On or before December 1 of each year, every employer should request of each employee a newly completed withholding exemption certificate for the ensuing calendar year.

14The Drug-Free Schools and Communities Amendments of 1989: Biennial Review
By the end of every-other calendar year, the University must conduct a biennial review covering the two-year period preceding that year. The biennial review must assess the University's efforts to comply with the annual distribution requirements of the Drug-Free Schools and Communities Act to 1) determine effectiveness and implement changes if necessary, and 2) ensure that sanctions are developed and enforced consistently. The University must keep a copy of the biennial review, as well as a "certification" signed by the President indicating that he has read the report and will act on its recommendations. These documents must be made available to the Dept. of Education upon request.

15Virginia Reporting of New Hires
Must report newly hired and re-hired employees to the state directory within 20 days of hire date. If multiple reports are filed electronically within the same month, they must be no less than 12 days and no more than 16 days apart. Thus, the reports should be filed bi-weekly throughout the year.

Every three years, the university must notify enrollees of the availability of the NPP and how to obtain it. Notification is also required whenever there is a change to the NPP. The most recent notification occurred in November 2009.