Patient-Centered Outcomes Research Institute (“PCORI”) Fees
Many plan sponsors of self-insured health plans are required to pay PCORI fees by July 31, 2016. Specifically, the fees must be paid by this July 31st for any plan year ending in 2015 (note, because the due date falls on a weekend, the due date would be extended to the next business day, August 1, 2016).
Important: You should identify what plans are subject to the requirement and whether the plan is self-insured or fully-insured.
What self-insured plans are subject to the requirement? Major medical coverage, certain health reimbursement arrangements (HRAs), and retiree coverage (including a health reimbursement arrangement for retirees-only) are subject to PCORI fees. For more detailed information, please see our Alert issued on July 19, 2013 at https://www.hitesmanlaw.com/client-alerts/alert_130719/.
Form 720 for Self-Insured Plan: The plan sponsor must file Form 720 and pay the required PCORI fee directly to the Internal Revenue Service (IRS). Third-party administrator (TPAs) cannot pay the fee on behalf of a plan. The Form 720 is available here: http://www.irs.gov/pub/irs-pdf/f720.pdf. Instructions for the form are available here: http://www.irs.gov/pub/irs-pdf/i720.pdf.
Form 720 for Fully Insured Plan: The issuer of a “specified health insurance policy” must file Form 720 and pay the required PCORI fee directly to the IRS. Consequently, the insurance carrier files the PCORI fee.
Amount of PCORI Fee: For a plan or policy year ending in 2015, the PCORI fee will be equal to $2.08 per covered life for each plan or policy year ending before Oct. 1, 2015 and $2.17 per covered life for each plan or policy year ending on or after Oct. 1, 2015.
If you have any questions or would like assistance with any of the foregoing items, please contact us.
Form 5500 Filing Deadline
In general, for plans subject to ERISA, Form 5500 filings are due seven months from the last day of the plan year. Note: Certain small plans are exempt from the filing requirement.
For a calendar year plan, the Form 5500 for the 2015 plan year is due on July 31, 2016 (note, because the due date falls on a weekend, the due date would be extended to the next business day, August 1, 2016), unless an extension is requested. If you need assistance with Form 5500 preparation and/or filing an extension, please contact us.
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The information contained in this ALERT is intended for general information purposes only and does not constitute legal advice relative to a specific situation.