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The Bloomberg BNA Federal Tax Blog is a forum for practitioners and Bloomberg BNA editors to share ideas, raise issues, and network with colleagues about federal tax topics. The ideas presented here are those of individuals and Bloomberg BNA bears no responsibility for the appropriateness or accuracy of the communications between group members.

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Friday, July 19, 2013

Self-Insured Plan Compliance Calendar: First Deadline for Patient-Centered Outcomes Research Trust Fund Fee Approaches

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The deadline is July 31, 2013, for sponsors of self-insured group health plans to pay Patient-Centered Outcomes Research (PCOR) Trust Fund fees to the IRS. The fee applies to accident and health coverage, retiree coverage, and COBRA coverage. It does not apply to excepted benefits or to programs that do not provide significant benefits in the nature of medical care or treatment.

The current fee, which is due for the plan year ending after September 30, 2012, is $1 multiplied by the average number of lives covered under the plan and any non-exempt flexible spending arrangements and health reimbursement arrangements. The fees are paid into the PCOR Trust Fund, which the Affordable Care Act established to finance a tax-exempt entity that conducts comparative clinical effectiveness research and provides information regarding the effectiveness, risks and benefits of various medical treatments.

There is some good news. First, IRS Associate Chief Counsel has advised that PCORI fees can be deducted as ordinary and necessary business expenses. Second, the annual fee is temporary and does not apply to plan years ending after September 30, 2019.

Also, if you provide health coverage to early retirees and took advantage of the reimbursements available under the Affordable Care Act’s Early Retiree Reinsurance Program, July 31, 2013, is the last day for you to submit reimbursement requests and also corrections to data inaccuracies that a participating sponsor knew or should have known of before May 1, 2013.

How are you keeping track of the Affordable Care Act deadlines that apply to you and your plans?

--Nadia Masri
Editor (Compensation Planning)

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