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COMPLIANCE UPDATE:
Patient-Centered Outcomes Research Institute (PCORI)
Fees
for HRAs and Certain Healthcare FSAs
The Harrison
Group Inc. has received several calls and emails from brokers and
clients with questions pertaining to client responsibilities with
regard to the PCORI fees for HRAs and certain Healthcare FSAs. We've
prepared the following Q & A for your benefit. This isn't meant to
be a comprehensive compliance guide, merely information which hopefully
makes your life a little easier. We have attached a completed sample Form
720 (only for the PCORI fee) as well as a portion of
the instructions for preparing the form. Please let the Harrison
Group know if you have any questions.
Q.
How much is
the fee?
A.
For
purposes of this summary the fee is $1 per covered person. There are
some exceptions. Please refer to the Form 720 instructions. You can
determine the number of total covered persons using one of the
acceptable methods described in the instructions. The simplest method
might be to add the number of participants at the end of the plan year
to the number of participants at the beginning of the plan year and
divide that total by 2. Then multiply the average by $1.
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For example:
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Participants on 1/1/12
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70
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Participants on 12/31/12
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80
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Average
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75
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The fee would then be $75.
Q.
Who must pay
the fee?
A.
Plan
sponsors of applicable self-insured health plans, such as Health
Reimbursement Arrangements and certain Healthcare Flexible Spending
Accounts.
Q.
What return
must be filed?
A.
Form
720 - Quarterly Federal Excise Tax Return
To
access the entire Q & A click the following to...<<read
more>>.
The
Harrison Group will automatically provide clients with a completed Form
720 if we are administering their Health Reimbursement
Arrangement (HRA). If we are not, there will be a $150 fee to
prepare Form 720 for your client.
As
always, please do not hesitate to contact us with any questions or
concerns.
Best
wishes for a continued safe and happy summer.
Richard H. Miller, Jr., CPA, CFP
President
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