Unique PCORI Fee Question

[5500Nerd]

Some use the 5500s to determine the count for the PCORI fee.  Our client had this scenario and question. I wondered if anyone could assist: 

• “Original” ERISA Plan Year : 6/1/19 – 5/31/20
• Short ERISA Plan Year: 6/1/20 – 6/30/20
• New ERISA Plan Year 7/1/20 -6/30/21 

As this group is technically self-funded for their medical plan, they are required to pay the PCORI fee.  This poses a challenge this year as they  actually have two plan years which end before October 1, 2020 as highlighted above which would need to be accounted for in the upcoming PCORI fee filing.  As we know, the IRS does require the PCORI fee to be paid for a short plan year. 

The Group typically uses the snapshot method, However,  the form does not provide a spot to account for multiple plan years (e.g. the average covered lives in tis case would need to be identical to “fit” within this form.).  Can you offer any guidance on how the group should address this short one month plan year when paying the PCORI fee?