Weekly Health Compliance Briefing

April 1, 2026

Note to Subscribers

 

While we do our best to provide timely updates, it is possible that the information shared in the newsletter may change after our publication deadline.

Health Notes

 

Reminder: A Change to the United States Post Office (USPS) Postmark Rules Could Impact Plan Notice Timing
Employers sponsoring group health plans should be aware of changes to the USPS postmark process that were implemented at the end of 2025. The changes could impact when government filings and participant disclosures are considered to have been sent on time

Generally, documents sent by mail are considered timely if they are postmarked on or before the applicable due date. Prior to the process change, mail dropped off at the post office or put in a public mailbox before the final pickup time would be postmarked that same day. Under the new process, a same-day postmark is no longer a certainty.

A postmark does not necessarily indicate when something was put in the mail, or, per the new rule, when the USPS took possession of a piece of mail. Rather, the postmark signifies the official date that the USPS “accepted custody” of a piece of mail. In other words, the postmark signifies the specific point in time when the USPS was in formal possession of the piece of mail at a processing facility, and it notates "the date of the first automated processing operation performed on that mailpiece.” The new rule was added due to changes in the USPS mail processing system (i.e., that not all items put in the mail will be sent to a facility and processed on the same day). The USPS notes that if a customer wants to ensure that a piece of mail receives a postmark on the same day of the mailing, the customer will have to deliver that piece of mail to a retail location and request a manual postmark at the retail counter.

Employee benefit plan disclosures to participants generally may be delivered electronically under Internal Revenue Service and Department of Labor rules. However, many disclosures are still delivered by mail, especially to participants no longer actively employed by the plan sponsor and other participants who have affirmatively opted out of electronic delivery. These disclosures include a host of participant communications from group health plans, such as summary plan descriptions, enrollment notices, required annual disclosures, benefit claims and appeals notices and determinations, and COBRA notices. Getting participant disclosures postmarked manually is likely infeasible for companies with more than a handful of employees, so plan administrators and/or their vendors may now need to build a few extra days into their delivery timeline to account for the potential postmark delay. 

Employers should review their mailing processes now and consider: (i) building in additional lead time to mailing schedules for deadline-sensitive documents, (ii) requesting manual postmarks at retail locations for mailings that are time-critical, or (iii) transitioning to electronic delivery where legally permissible.

Aon Publications

 

The All About Leave Newsletter—March 2026 Edition
The All About Leave Newsletter focuses on what employers need to know about state and local laws that regulate paid sick leave, paid family and medical leave, and paid leave for any reason.

The March 2026 edition of the All About Leave Newsletter is available here.