Employers who sponsor self-insured coverage—including HRAs and certain FSAs—are responsible for filing and paying the Patient-Centered Outcomes Research Institute (PCORI) by July 31st of the calendar year following the end of the applicable plan year. Fees for plan years that ended in 2019 are due July 31, 2020.
The fee is paid as an excise tax, submitted to the IRS once per year on the second quarter Form 720. The fee amount is based on the average number of covered individuals for the applicable plan year. The per-participant fee is adjusted each year for inflation.
On June 8, 2020, the IRS issued Notice 2020-44, which increases the fee amount for plan years ending on or after Oct. 1, 2019, and before Oct. 1, 2020. It also provides transition relief for calculating the average number of lives covered under the plan for this period.
- For plans ending January 1, 2019 through September 30, 2019, the fee is $2.45 per covered life.
- For plans ending October 1, 2019 through December 31, 2019, the fee is $2.54 per covered life.
Please note: Marshall & Sterling will provide participant counts and detailed instructions for making payment to our affected clients to assist with this filing. You will be contacted directly with this information shortly, if applicable.