The Affordable Care Act requires health insurance issuers and self-insured plan sponsors to pay Patient-Centered Outcomes Research Institute (PCORI) fees. The fees are reported and paid annually using IRS Form 720.

For plan years ending in 2024, Form 720 and full payment of the PCORI fees are due by July 31, 2025.

The PCORI fee applies to plan or policy years ending after Sept. 30, 2012, and before Oct. 1, 2029.

Calculating the PCORI Fee Payment

In general, the PCORI fees are assessed, collected and enforced like taxes. The PCORI fee is imposed on an issuer of a “specified health insurance policy” and a plan sponsor of an “applicable self-insured health plan” based on the average number of lives covered under the plan. Final rules outline several alternatives for issuers and plan sponsors to determine the average number of covered lives.

Using Part II, Number 133 of Form 720, issuers and plan sponsors report the average number of lives covered under the plan separately for specified health insurance policies and applicable self-insured health plans. That number is multiplied by the applicable rate for that tax year ($3.47 for plan years ending on or after Oct. 1, 2024, and before Oct. 1, 2025, or $3.22 for plan years ending on or after Oct. 1, 2023, and before Oct. 1, 2024). The fees for specified health insurance policies and applicable self-insured health plans are then combined to equal the total tax owed.

Employer Action Steps

To assess their obligations, employers should:

• Determine which plans are subject to the PCORI fees.
• Assess plan funding status (insured versus self-insured) to determine whether the issuer or the employer is responsible for the fees.
• Select an approach for calculating average covered lives for self-insured plans.

The IRS provides helpful resources, including a chart on how the fees apply to specific types of health coverage or arrangements.

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