Yesterday I spoke at the 2013 Legislative Meeting of the Society of Professional Benefit Administrators (SPBA) here in Washington DC. One of my co-speakers was Dr. Sharon Arnold from CCIIO – one of the architects of the reinsurance fee program. We were very honored to have such a high-level and knowledgeable person on the panel. The meeting also featured representatives from the IRS discussing the Patient Centered Outcome Research (PCOR) Fee. My discussion focused on the differences between the PCOR Fee and the transitional reinsurance fee. Many of you have already seen and enjoyed our comparative chart (attached).
Two quick updates from the meeting. First, for the PCOR Fee, this fee is included and paid via IRS Form 720. This form has not been updated yet, and sponsors should not use the current IRS Form 720 on the IRS website. This has created much heartburn in the benefits community because the fee is due by July 31, 2013. The IRS stated that the form will be updated for the PCOR Fee and will be released “prior to” the due date. Based on the IRS update schedule, I expect the updated form to be available around June 1st. Second, for the reinsurance fee, plans are required to inform HHS of covered life counts by November 15th of each year. Dr. Arnold indicated that this process is still in development, but indicated that the process will be totally electronic, most likely via an HHS website.
Disclaimer
While we are pleased to have you contact us by telephone, surface mail, electronic mail, or by facsimile transmission, contacting Kilpatrick Townsend & Stockton LLP or any of its attorneys does not create an attorney-client relationship. The formation of an attorney-client relationship requires consideration of multiple factors, including possible conflicts of interest. An attorney-client relationship is formed only when both you and the Firm have agreed to proceed with a defined engagement.
DO NOT CONVEY TO US ANY INFORMATION YOU REGARD AS CONFIDENTIAL UNTIL A FORMAL CLIENT-ATTORNEY RELATIONSHIP HAS BEEN ESTABLISHED.
If you do convey information, you recognize that we may review and disclose the information, and you agree that even if you regard the information as highly confidential and even if it is transmitted in a good faith effort to retain us, such a review does not preclude us from representing another client directly adverse to you, even in a matter where that information could be used against you.
