Tuesday, July 11, 2017

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Benefits Compliance Podcast Episode 12

This week Suzanne Spradley and Chase Cannon give a quick update on the fate of the Better Care Reconciliation Act. The two further explore one aspect of the Republican effort to stabilize the individual market, called the invisible risk sharing pool, which is meant to help insurers take on the increased costs associated with covering high-risk individuals.

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Reminder: Form 5500 Filing for Calendar Year Plans Due July 31

Applicable plan sponsors must file Form 5500-series returns on the last day of the seventh month after their plan year ends. As a result, calendar-year plans generally must file by July 31 (reporting on the 2016 plan year). Plans may request a 2 1/2 month extension to file by submitting Form 5558, “Application for Extension of Time to File Certain Employee Plan Returns,” by that plan's original due date.

As a reminder, group health plans sponsored by a governmental or church entity are not required to file a Form 5500, as those plans are not subject to ERISA. Additionally, unfunded, insured or combination unfunded and insured health plans with fewer than 100 participants on the first day of the plan year are also exempt from the filing.

NFP has vendors available to assist with filings. Ask your advisor if you need assistance.

Forms and Instructions »
Form 5500 EFAST2 »
Form 5558, Extension of Time »

Reminder: PCOR Fee, Form 720 Filing Due July 31

PPACA imposed the PCOR fee on health plans to support clinical effectiveness research. The PCOR fee applies to plan years ending on or after Oct. 1, 2012, and before Oct. 1, 2019. The PCOR fee is generally due by July 31 of the calendar year following the close of the plan year.

PCOR fees are required to be reported annually on Form 720, “Quarterly Federal Excise Tax Return,” for the second quarter of the calendar year. The due date of the return is July 31.

Plan sponsors subject to PCOR fees but not other types of excise taxes should file Form 720 only for the second quarter. No filings are needed for the other quarters for such employers. The PCOR fee can be paid electronically or mailed to the IRS with the Form 720 using a Form 720-V payment voucher. According to the IRS, the fee is tax-deductible as a business expense.

The PCOR fee is generally assessed based on the number of employees, spouses and dependents that are covered by the plan. For plan years ending in 2016 on or before Sept. 30, 2016, the fee is $2.17 multiplied by the average number of lives covered under the plan. For plan years ending between Oct. 1, 2016, and Oct. 1, 2017, the fee increases to $2.26. Form 720 and corresponding instructions were revised to reflect the increased fee.

As a reminder, the insurer is responsible for filing on a fully insured plan. The employer plan sponsor is responsible for filing on a self-insured plan, including an HRA. A stand-alone dental or vision HRA would be accepted and not subject to the PCOR fee.

Form 720 »
Form 720 Instructions »