2023 PCORI Fees Due July 31, 2024

For employers that have a medical plan with an HRA and/or are self or level-funded, this is a reminder your 2023 PCORI fee is due July 31, 2024.

 

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

 

Form 720 and full payment of the PCORI fees are due by July 31 of each year, and generally covers plan years that end during the preceding calendar year. For plan years ending in 2023, the PCORI fees are due by July 31, 2024.

 

Who Does This Apply To?

The entity responsible for paying the PCORI fee depends on whether the plan is fully insured or self-insured.

  • For fully insured health plans, the issuer (carrier) of the health insurance policy is required to pay the fees.
  • For self-insured health plans (including HRA's), the fees are to be paid by the plan sponsor (employer).

 

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 a number of 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 then multiplied by the applicable rate for that tax year ($3.00 for plan years ending on or after Oct. 1, 2022, and before Oct. 1, 2023, 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 fee owed.

 

Action Steps

Directly below, you will find a PCORI fee payment schedule based on plan year start date. For easy reference, we’ve also included links to relevant forms and documents.

 

Payment Schedule & Resources

Plan Year                     Fee Per Average Covered Life       Due Date
2/1/22 – 1/31/23 $3.00 July 31, 2024
3/1/22 – 2/28/23 $3.00 July 31, 2024
4/1/22 – 3/31/23 $3.00 July 31, 2024
5/1/22 – 4/30/23 $3.00 July 31, 2024
6/1/21 – 5/31/23 $3.00 July 31, 2024
7/1/22 – 6/30/23 $3.00 July 31, 2024
8/1/22 – 7/31/23 $3.00 July 31, 2024
9/1/22 – 8/31/23 $3.00 July 31, 2024
10/1/22 – 9/30/23 $3.00 July 31, 2024
11/1/22 – 10/31/23 $3.22 July 31, 2024
12/1/22 – 11/30/23 $3.22 July 31, 2024
1/1/23 – 12/31/23 $3.22 July 31, 2024

 

If you have questions related to this update, please contact your North Risk Partners advisor. Don’t have an advisor? No problem. We’ll help you find one.

This regulatory update is not intended to be exhaustive nor should any discussion or opinions be construed as legal advice. Readers should contact legal counsel for legal advice.

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