Healthcare Reform
Federal Updates
Retirement Update
Announcements
Reminder: Form 5500 Filing for Calendar Year Plans Due July 31
Each year, PPI Benefit Solutions files the Annual Return/Report Form 5500 Schedule A for the ACSA and BIEB Group Insurance Trusts. This filing includes all coverages provided and administered through the Trusts, eliminating the need for Trust members to file for these coverages. Clients may be responsible for filing Form 5500 for benefits and products purchased outside of the ACSA or BIEB Trusts, as well as any employer-sponsored fringe plans such as cafeteria plans, educational assistance plans, or legal plans.
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 of this year (reporting on the 2019 plan year). Plans may request a two-and-a-half-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 aren’t required to file a Form 5500, as those plans aren’t 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.
Forms and Instructions »
Form 5500 EFAST2 »
Form 5558, Extension of Time »
PCOR Fee, Form 720 Filing Due July 31
The ACA imposed the PCOR fee on health plans to support clinical effectiveness research. The PCOR fee applies to plan years ending on or after October 1, 2012, and before October 1, 2029. 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. Plan sponsors that are subject to PCOR fees but no 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 is generally assessed based on the number of employees, spouses and dependents that are covered by the plan. For plan years ending in 2019 on or before October 1, 2019, the fee is $2.45 multiplied by the average number of lives covered under the plan. For plan years ending between October 1, 2019, and October 1, 2020, the fee increased to $2.54. Form 720 and corresponding instructions were revised to reflect the increased fee.
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.
As a reminder, the insurer is responsible for filing and paying the fee for 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 excepted and wouldn’t be subject to the PCOR fee.
COVID-19-Related Benefits Compliance Resources Available
The Benefits Compliance team has provided a number of resources that are available for assistance during the COVID-19 crisis. Information presented through our resources is subject to change pending additional guidance from the DOL, IRS or other state or federal regulatory agencies.
Return to Work Resources
Returning to the Workplace Amid COVID-19: Potential Issues and Practical Guidance FAQ »
Benefits Compliance Return to Work FAQ »
Returning to Work: A Blueprint for Moving Forward + Vendor Guide »
Other Resources
COVID-19 Deadlines and Extensions: Quick Reference Chart quick reference chart »
FAQs on Benefits and Compliance and COVID-19 »
Families First Coronavirus Response Act (FFCRA) Flowchart »
COVID-19 State Quick Reference Chart »
DOL Issues COVID-19 Relief via Certain Notice Extensions for Employee Benefit Plans »
Compliance Considerations on Insurance Carrier Refunds in the COVID-19 Environment »
FAQ
With all of the recent changes related to COVID-19, what are an employer’s choices related to a health FSA and dependent care FSA?
State Updates
Alabama
Indiana
New York
This material was created by PPI Benefit Solutions to provide accurate and reliable information on the subjects covered but should not be regarded as a complete analysis of these subjects. It is not intended to provide specific legal, tax or other professional advice. The service of an appropriate professional should be sought regarding your individual situation. PPI does not offer tax or legal advice. "PPI®" is a service mark of Professional Pensions, Inc., a subsidiary of NFP Corp. (NFP). All rights reserved.