Upcoming Deadlines For PCORI Fee Payment and Form 5500 Filing

Upcoming Deadlines For PCORI Fee Payment and Form 5500 Filing

For many employers, two crucial federal compliance deadlines are coming up on July 31, 2018—payment of the Patient-Centered Outcomes Research Institute (PCORI) fee and filing of Form 5500.  The PCORI fee requirement applies to self-funded group health insurance plan sponsors, who must file Form 720 and make payment to the Internal Revenue Service (IRS) by that date.  Also, employee benefit plans that are subject to the Employee Retirement Income Security Act (ERISA) that have more than 100 participants and begin their annual plan year on January 1 must jointly file Form 5500 with the IRS, the Pension Benefit Guaranty Corporation and Department of Labor (DOL) by July 31.

The PCORI fee is a small federal assessment on private health plans to fund a government-sponsored center to research the effectiveness of various medical care treatments.  Health insurance carriers are responsible for paying the fee on behalf of all fully-insured health plan participants.  However, all businesses that operate self-insured medical plans, including health flexible spending accounts (FSAs) that do not qualify as an excepted benefit plans and health reimbursement arrangements (HRAs), have to pay the PCORI fee directly.  The total number of people covered by the group plan, including all dependents, determines the amount of the tax and there are several methods an employer plan can use to make that count.  For the 2017 plan year, the amount is $2.39 per covered life. To pay for this assessment, employers must complete and file Form 720.  Employers may submit this excise tax form quarterly, but PCORI fees are due just with the second quarter’s form.  If you need more detailed information and assistance about PCORI fee filing, please contact your KTB representative.

Form 5500 is an annual report of benefit plan information made to the federal government by employer plan sponsors that are bound by ERISA.  Almost all employer group health plans with fewer than 100 participants qualify for a reporting exemption, but bigger fully insured and self-funded plans must file this report annually or face significant penalties from both the IRS and the DOL.  Plan sponsors must submit Form 5500 through the DOL’s electronic submission system, known as EFAST2.  The deadline for this filing is the last day of the 7th month after the employer plan year concludes, so for different plans it varies.  However,  for all businesses that start their health plan year on January 1st, the deadline is July 31, 2018.

If a business needs more time to finish their submission, then they may file Form 5888 before the original due date of their Form 5500 and get an automatic 2½-month extension.  If an employer plan has wrapped its various employee benefit offerings together into one comprehensive plan document, then only one Form 5500 must be filed, but if different benefit components have separate plan documents, then multiple forms may need to be completed.  If you need assistance with your form 5500 filing, please contact your Kistler Tiffany Benefits Consultant.