Q. I have a client who’s plan year runs from 10/1 to 9/30. How do I determine their 2023 PCORI fees? I can’t determine if in July they’ll be charged $2.79, or $3.00, based on their prior plan year end date of 9/30/22.
A. This is always a confusing one with non-calendar year plans. If the plan year ends between January 1 and September 30, the PCORI fee is based on the rate set up for the prior calendar year ($2.79). For plan years that end between October 1 and December 31, you use the PCORI rate in effect for the current year ($3.00 in your example). So I believe your client should be using the $2.79 rate for the plan year ending 9/30/22.
Q&A 3 in the IRS FAQ may be helpful.
Responses to compliance questions provided by Kutak Rock.