April 1, 2025
Paul Van Brunt, Associate Director, Benefits Compliance
As 2025 presses onward, there are several significant federal deadlines for health and welfare plans quickly approaching. Satisfaction with these important regulatory reporting requirements may require operational and administrative planning.
Key among these regulatory mandates are payment of the annual Patient-Centered Outcomes Research Institute Trust Fund (“PCORI”) Fee and related reporting on IRS Form 720, preparation and filing of the annual Form 5500 submissions, and the federal transparency-related reporting obligations focused on prescription drug reporting to the Centers for Medicare & Medicaid Services (“CMS”). Below, we evaluate the performance of each requirement:
- PCORI Fees: Established under the Affordable Care Act, payment of PCORI fees and agency reporting to the Internal Revenue Service is due annually by July 31. Issuers and plan sponsors of applicable self-insured health plans (including level-funded health plans and Health Reimbursement Accounts (“HRAs”) are required to pay these fees by completing and submitting IRS Form 720. The per participant per year fee fluctuates from year to year, based upon annual modifications made to National Health Expenditures, as determined and enforced by the IRS. Assure your organization is prepared to calculate applicable fees based on the average number of covered lives enrolled in applicable health and welfare benefit plans, and that your organization has installed operational and administrative methodologies for calculating, reporting, and paying the applicable assessed PCORI fees.
- Form 5500 Filings: Respecting employer plan sponsors of self- or level-funded health and welfare plans with 100 or more participants (as of the first day of the applicable plan year), a Form 5500 submission is due for submission for each qualifying plan (and/or the employer’s wrap plan) on or before the last day of the 7th month following the end of the applicable reporting year. For calendar year plans, this means the Form 5500 submission is due no later than July 31. The Form 5500 is designed to report certain administrative, demographic, and financial information to the federal government, as well as to plan participants and beneficiaries. Form 5500 due diligence requires the archiving of accurate and timely recordkeeping through the year, to avoid headaches at reporting time. Also, remember that Forms 5500 must be submitted on an electronic basis, via the US Department of Labor’s EFAST2 web-based filing program, so be prepared to access, operate, and report under the applicable online portal.
- Prescription Drug Data Collection (RxDC) Reporting: Employer plan sponsors of health and welfare plan offerings that provide, as a covered benefit, prescription drug coverage (“Rx”), must annually submit a Prescription Drug Pricing Transparency Report (“RxDC”) to the Centers for Medicare & Medicaid Services (“CMS”) (submission of the report for the 2024 plan year is due no later than by June 2, 2025). This regulation requires the plan sponsor or issuer to disclose cost and usage data relative to prescription drugs covered by the plan, changes in drug prices, and the effects of such modifications upon premiums and out-of-pocket costs for beneficiaries. The RxDC reporting requirement is part of a larger healthcare transparency initiative designed to enhance price transparency, curb rising drug costs, and protect consumers from excessive out-of-pocket costs.
The foregoing compliance requirements necessitate mindful record-keeping, efficient utilization of resources, and precision as to performance. To avoid penalties and to ensure seamless organizational governance, plan sponsors should take time now to now to prepare for the satisfaction of these important and significant reporting obligations.
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