The date-driven services together: COBRA, ACA, PCORI and Medicare reporting.
These four services share one trait: they run on fixed dates, and a missed date has a price. Arranging them together puts the notices, filings and fees on one calendar with one provider responsible.
Four services, one calendar.
Each has its own guide with the rules behind it.
COBRA Administration
Notices within set days of a qualifying event, and the billing and records behind continuation coverage.
ACA Employer Reporting
Forms 1094-C and 1095-C furnished to employees and filed with the IRS each year.
PCORI Fee Reporting
An annual fee on self-funded plans and HRAs, reported on Form 720 each July.
Medicare Secondary Payer Reporting
Reporting Medicare beneficiaries on your plan to CMS.
When each one runs.
All Year
COBRA notices follow qualifying events as they happen. See the notice rules.
Early in the Year
ACA forms go to employees and to the IRS. See the furnishing deadline.
July
The PCORI fee is due by July 31. See who owes it.
Why one provider and one calendar usually works better.
Each of these four services has a separate rulebook but follows the same pattern: a trigger, a deadline and a record. When different people own each one, the dates are easy to lose between handoffs. When one provider owns the calendar, the dates move from the employer’s memory to a schedule that someone is paid to follow.
This does not remove the employer’s responsibility. You still supply accurate data, such as hire and termination dates, hours worked and coverage offered. The bundle is useful because the data requirements overlap, so one clean data feed supports all four services. Confirm which of the services apply to your plan and size with your advisor or counsel.
The questions employers ask.
Five questions to settle first.
Why bundle these four?
They all run on fixed dates and all depend on the same enrollment and eligibility data, so one provider working from one file is less likely to miss one.
Do small employers file ACA forms?
Employers with 50 or more full-time equivalent employees must report, and self-funded employers of any size may report coverage. We check where you fall.
Who owes the PCORI fee?
Insurance carriers pay it for insured plans. Sponsors of self-funded plans and many HRAs pay it themselves and file Form 720.
What is Medicare Secondary Payer reporting?
Plans identify Medicare beneficiaries to CMS so that payment order is coordinated correctly. The guide explains who reports.
Does it come with hold-harmless protection?
Protection of up to $1,000,000 is available on covered compliance services under the arrangement we can offer, subject to the written terms.
What data does the employer need to provide?
Typically employee hire and termination dates, coverage elections, hours or eligibility information and any qualifying events. The exact list depends on the services.
What if we miss a date?
Contact your compliance provider or counsel promptly. The consequence depends on which date was missed, and acting quickly usually gives more options.
Ready? Upload your renewal, or talk it through with someone first. No cost, no obligation.
General information about compliance services, not legal or tax advice. Plan-specific questions belong with your counsel, and we will bring them in.
Related guides.
Plan Compliance Basics Bundle
ERISA, HIPAA and FMLA together.
ICHRA Compliance Bundle
What an ICHRA brings with it on the compliance side.
Compliance Service Bundles for Employers
All the bundles in one place.
Where the Rules Come From.
The laws and rules named on this page link to the statute or regulation they come from. This is general information, not legal or tax advice, and rules change, so check the current text.
ACA Employer Reporting (26 U.S.C. 6056)
The information reporting rules for large employers.
Fee on Self-Insured Health Plans (26 U.S.C. 4376)
The PCORI fee plan sponsors pay and how lives are counted.
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