Employee Benefits

Legal Alert: IRS Releases Updated Form 720 Used For PCORI Fee Payments

June 16, 2020

As we recently reported, on June 8, 2020, the IRS released the applicable PCORI fee for plan years ending between October 1, 2019 and September 30, 2020.  As we indicated in that alert, an updated Form 720 had not yet been released and, therefore, employers were advised to wait to file their PCORI fees until the IRS released the updated form.  Late last week, the IRS issued the updated Form 720, which is the April 2020 Revised form. Employers who sponsored a self-funded health plan, including an HRA, with a plan year that ended in 2019 should use this updated Form 720 to pay the PCORI fee by the July 31, 2020 deadline.



As a reminder:




    
  • The insurance carrier is responsible for paying the PCORI fee on behalf of a fully insured plan. 

  • 
  • The employer is responsible for paying the fee on behalf of a self-insured plan, including an HRA.  In general, health FSAs are not subject to the PCORI fee.

  • 
  • Plans that ended between January 1, 2019 and September 30, 2019 use Form 720 to pay their PCORI fee of $2.45 per covered life. 

  • 
  • Plans that ended between October 1, 2019 and December 31, 2019, use Form 720 to pay their PCORI fee of $2.54 per covered life. 



 



The information provided in this alert is not, is not intended to be, and shall not be construed to be, either the provision of legal advice or an offer to provide legal services, nor does it necessarily reflect the opinions of the agency, our lawyers or our clients.  This is not legal advice.  No client-lawyer relationship between you and our lawyers is or may be created by your use of this information.  Rather, the content is intended as a general overview of the subject matter covered.  This agency and Marathas Barrow Weatherhead Lent LLP are not obligated to provide updates on the information presented herein.  Those reading this alert are encouraged to seek direct counsel on legal questions. © 2020 Marathas Barrow Weatherhead Lent LLP.  All Rights Reserved.

    Alera Group, Inc. is aware that there are persons fraudulently impersonating our company by using fake internet domains that appear to look like our legitimate services. If you are contacted by someone claiming to work for Alera Group, or any of our partners, please carefully review the email address and domain. If you have a relationship with our company, please contact us directly and not through any information that is provided in such an email. Please be extremely careful in responding to such emails with personal and financial information, sharing passwords, or any other information of value. Alera Group, or any of our partners, will never send ACH instructions via email and thus we strongly recommend that you verify the authenticity of each wire transfer request by calling your Alera Group contact using the number you have previously called.