Four Things Land on a Nevada Employer's Desk Before October 15

By Mary Jones, licensed independent broker, Henderson. Last reviewed September 22, 2026.

September 30. October 2. October 2 again. October 14.

Four dates inside the next four weeks, and every one lands on the desk of somebody who opened a business to do something other than read insurance mail. I call it the October pile. It shows up every fall. This year it's taller. Most of it takes ten minutes once you know what you're holding.

Up front, the way I always do it: if you move your group coverage through me, the carrier pays me. Everything in this post you can do yourself, free. A couple of pieces your carrier is supposed to hand you, and I'll say which.

The short version. A rebate check may land by September 30. Some of it may not be yours. Owners running a QSEHRA or an ICHRA on a calendar year owe employees a notice by Friday, October 2, which happens to be the day the state posts 2027 small-group plans, after carriers asked for about 12% more. Last comes the Medicare Part D notice. October 14, and the test behind it got harder this year.

September 30: the check that isn't all yours

Insurers have to spend at least 80 cents of every small-group premium dollar on medical care and quality improvement. Fall short over a three-year average, and the difference comes back. By September 30. Nationally that's about $759 million this year, the smallest pot since 2018, so don't plan a remodel around it. Plenty of Nevada groups will get nothing.

Here's what owners miss when a check or a premium credit does arrive. Your employees get a letter saying you received it. If they pay part of the premium, part of that money is theirs, and the Labor Department's position is that their share should be used for them within three months. Lower their next premiums, or pay it back directly. Then put a note in the file saying how you split it and why.

Depositing it and forgetting it? Wrong answer. The letter your employees got has a date on it.

October 2: the 90-day letter

This one is for owners who reimburse employees for their own health plans through a QSEHRA or an ICHRA, or who plan to start one January 1.

The rule: a written notice to every eligible employee, at least 90 days before the plan year begins. Count back from January 1 and you land on a Saturday, October 3. Friday the 2nd, then. Skip it on a QSEHRA and the penalty is $50 per employee, capped at $2,500 a year. Small money. A dumb way to spend it.

The notice tells each employee how much they can be reimbursed, and that they have to report the amount if they apply for a marketplace tax credit. That second part carries more weight than it used to. The repayment caps on those credits are gone for 2026. An employee who takes a credit they weren't entitled to, because nobody mentioned the HRA, pays back every dollar in April.

If you use an HRA vendor, they probably generate the notice. Check that it went out. "Probably" is doing a lot of work in that sentence.

October 2, again: next year's prices

Same day, different stack. The Division of Insurance adds 2027 small-group plans to its website on October 2. Carriers asked for roughly 12% more on average, and if your group renews January 1, your renewal packet is either on your desk or about a week out.

Twelve percent is an average of asks, and an ask is not your renewal. Small-group rates in Nevada are built from your employees' ages and the plan you picked, then adjusted for where you are, so two shops on the same street can open very different envelopes.

This is the one item in the October pile where I earn my keep. A renewal is an offer. You're allowed to answer it: other carriers, a different plan design, an HRA in place of a group plan, or the same plan with a different contribution split. None of that has to wait for January.

October 14: the Medicare letter nobody mentioned

If your health plan covers prescriptions, you owe a notice to everyone on it who is eligible for Medicare. Every employer. Any size. It says whether your drug coverage is at least as good as Medicare Part D, which the rules call creditable, and it has to be out before October 15.

Most owners with six employees have never heard of it. The stakes aren't even yours. A 66-year-old who stays on your plan believing the drug coverage counts, when it doesn't, pays a late penalty on Part D for as long as they have it.

Here's what changed. The old shortcut test for creditable coverage is retired for 2027 plan years. Under the new one, a plan has to be designed to pay at least 73% of drug costs on average, up from 60% under the old method. Some plans that passed for years won't pass now.

You don't run that math. On a fully insured plan the carrier makes the determination and owes you the answer. So the job is two steps: get the 2027 creditable coverage status in writing, from your carrier or from me, then send the notice. CMS publishes model letters. The easy way is to hand one to everybody on the plan, so nobody has to guess who turned 65. There's also a short online disclosure to CMS due within 60 days after the plan year starts.

The part that depends on headcount

Everything above applies to a shop with four people. Other rules only switch on at 50 full-time-equivalents, and the affordability line for those employers moves to 10.22% of household income in 2027, the first time it has crossed ten. Anywhere near 50? Not sure how part-timers count? The Employer Obligation Finder sorts that out in a couple of minutes. Starting from zero on group coverage? The small business guide is where I'd begin.

And if the October pile is only one of your piles, payroll and workers' comp being the loudest of the others, I wrote about who I call for the rest of it, referral credit disclosed at the top.

If you'd like a second set of eyes on a renewal, or the creditable coverage letter from your carrier hasn't shown up, call me at (702) 379-9084 or book a time. No cost.

October 14 is the date that costs somebody else money when it's missed. I'd start there.

Quick answers

When are MLR rebates due in 2026? By September 30, 2026. Insurers that spent less than 80% of small-group premiums on care, averaged over three years, owe the difference as a check or a premium credit.

What is the QSEHRA and ICHRA notice deadline for a January 1, 2027 plan year? At least 90 days before the plan year. Ninety days before January 1, 2027 is Saturday, October 3, so plan on Friday, October 2.

When is the Medicare Part D creditable coverage notice due? Before October 15 each year, which makes October 14, 2026 the last day.

Does the Part D notice apply to a business with five employees? Yes. It applies to any employer whose group health plan includes prescription drug coverage, whatever the size.

How much are Nevada small-group rates going up in 2027? Carriers asked for about 12% on average. Those are proposed rates. The Division of Insurance posts 2027 small-group plans on October 2.

Sources: KFF on 2026 rebates; Nevada Division of Insurance, small employer market; small-group filings as compiled by ACA Signups; Brown & Brown on the 2027 creditable coverage rule.

We do not offer every plan available in your area. Any information we provide is limited to those plans we do offer in your area. Please contact HealthCare.gov to get information on all of your options. This article is general information, not legal, tax, or financial advice. Confirm your own deadlines with your plan documents or your advisor. Mary Jones, Jones True Insurance Solutions, Henderson, NV. NPN #20192176.