USA: Alliant FAQ of the Week

The following FAQ of the Week questions were provided by Alliant, Asinta’s partner in the United States.

Q. Can a company match an employee’s pre-tax HSA contributions?

A. Yes, as long as HSA contributions are made “through a cafeteria plan.” If a company’s cafeteria plan permits participants to make pre-tax salary reduction contributions to their HSAs, any matching employer contributions made by a company would also be treated as made “through a cafeteria plan.” When contributions are made through the cafeteria plan they are not subject to the very strict Comparability rules. Instead they would be subject to the Code § 125 nondiscrimination requirements. Those requirements do not generally create problems for most employer contribution strategies. For more information on Comparability rules and the cafeteria plan exception see our Alliant Insight.

Q. My client had a short plan year – from 06/01/15 through 12/31/15. The prior plan year was from 06/01/14 through 05/31/15. They are now in a calendar plan year which began on 01/01/16 and will last through 12/31/16. How do they properly pay the PCORI fee?

A. The PCORI fee is paid on a plan year by plan year basis. The plan sponsor would pay the PCORI fee for both plan years ending on 05/31/15 and 12/31/15 in 2016. In 2017, the plan sponsor would pay for the full 2016 calendar year.

6/1/14 – 5/31/15: $2.08 – due 7/31/16
6/1/15 – 12/31/15: $2.17 – due 7/31/16
1/1/16 – 12/31/16: TBD – due 7/31/17