July 23, 2015

Attention Brokers:

 

We are committed to helping you and your clients comply with the provisions of Health Care Reform. That's why you are receiving advance notice of the following reminder we are sending to our employers by the end of this week. If you have any questions about this notice, please contact your account manager or your Health Care Reform Program Manager and Broker Liaison, Kerri McKeown. 

 

Patient-centered Outcomes Research Institute (PCORI) fee

 

At Highmark Blue Cross Blue Shield, we are committed to keeping you informed about the Affordable Care Act (ACA) and how Health Care Reform affects you and your employees.

 

We'd like to remind you that the annual PCORI fee is due at the end of July. The PCORI fee, created by the ACA, supports clinical effectiveness research through 2019.

 

 

Who is responsible for paying the fee? 

 

If you offer a...           
You need to...
Fully-insured
group health plan

Do nothing; Highmark will file and pay the fee. 

Fully-insured
group health plan
with an HRA or FSA

The PCORI fee applies to both the fully-insured group health plan and the HRA or FSA. This is because the regulations consider HRAs and many FSAs types of self-insured group health plans.

 

Note: The fee does not apply to HRA or FSA arrangements that satisfy the requirements for being treated as excepted benefits.

 

File Form 720 and pay the required PCORI fee to the IRS for the HRA or FSA portion of your company's coverage by July 31, 2015. Highmark will calculate and pay the fee for the insured group health plan portion of coverage for Highmark fully-insured group customers and individual policyholders. 
Self-insured
group health plan
File Form 720 and pay the required PCORI fee directly to the IRS by July 31, 2015.
Self-insured
group health plan
with an HRA or FSA

If you offer a self-insured group health plan on the same plan year as the HRA or FSA, then any covered lives already counted for the group health plan will not need to be counted and paid for again with the HRA or FSA plan.

 

If your self-insured group health plan does not follow the same plan year as the HRA or FSA, then covered lives already counted for the group health insurance plan will need to be counted and paid for again with the HRA or FSA plan.


 

How to calculate the fee

 

For plan years ending October 1, 2013--September 30, 2014, the fee is $2.00 per covered life.

For plan years ending October 1, 2014--September 30, 2015, the fee is $2.08 per covered life.

 

"Covered lives" generally includes all enrollees in a plan, including spouses and dependents, but there are some exceptions for HRAs and FSAs. For more information on how you can determine covered lives, see Part II on page 8 of the instructions for Form 720, the IRS Questions and Answers page or the final regulations.

 

 

How to file and pay the fee

 

Employers file and pay the PCORI fee using IRS Form 720, the Quarterly Federal Excise Tax Return, electronically through the Electronic Federal Tax Payment System (EFTPS) or by mail to:

Department of the Treasury

Internal Revenue Service

Cincinnati, OH 45999-0009

 

This tax is deductible as a business expense under section 162, according to the IRS memo released on May 31, 2013.

 

 

The deadline

 

The fee needs to be filed and paid in full by July 31, 2015


We will reach out to you if new information becomes available. In the meantime, please visit our Health Care Reform website. If you have any questions, or for more information, please contact your account manager.

This content is provided solely for informational purposes. It is not intended as and does not constitute legal advice. The information contained herein should not be relied upon or used as a substitute for consultation with legal, accounting, tax and/or other professional advisors.

 

Self-funded group benefits may be different from the benefits and services described here. See your Summary Plan Description for complete details of your coverage.

 

Constant Contact is an independent and/or a separate company from Highmark Blue Cross Blue Shield and provides email marketing services to Highmark Blue Cross Blue Shield.

 

The information in this email is for employers who offer plans through Highmark Blue Cross Blue Shield, First Priority Life Insurance Company® or First Priority Health®, which are licensed affiliates of Highmark Blue Cross Blue Shield.

 

Highmark Blue Cross Blue Shield, First Priority Life Insurance Company and First Priority Health are independent licensees of the Blue Cross Blue Shield Association.