Issue Brief: PCORI Fee Reminder – Updated Form 720
June 1, 2022
The IRS released a new Form 720 with updated dates and fees on Line 133 for reporting the PCORI fees. You can find the form, with a revision date of June 2022, here.
Employers who sponsored self-funded medical plans that ended sometime during 2021 are required to report and pay the ACA Patient-Centered Outcomes Research Institute (PCORI) fees no later than July 31, 2022. The Form 720 should be filed for the 2nd quarter ending June 30th, 2022.
Background
General summary information for PCORI fees can be found here.
Health insurance carriers pay the fee on behalf of fully-insured plans, but employers are responsible for reporting and paying the fee for any self-funded group health plans, including HRAs. The PCORI fee applies to most group health plans, but not to excepted benefits. The IRS published a chart that describes the different types of plans subject to the fee.
The fee is paid using quarterly excise tax Form 720, Line 133, and must be paid by July 31st of the year following the last day of the plan year. We recommend reporting the PCORI fee in the 2nd quarter of the calendar year following the end of the plan year, rather than filing sooner, to avoid any confusion for the IRS over which plan year the reporting applies to. If any corrections need to be made for prior years, use Form 720X.
Fee Amount
Payment amounts due in 2022 will differ based on the employer’s plan year. The IRS put together a chart showing applicable fee amounts depending on the plan year end date The fees due in July 2022 are as follows:
- $2.66 per covered life for plan years ending in January – September 2021.
- $2.79 per covered life for plan years ending in October – December 2021.
Calculating the Average Covered Lives
Self-funded plans may use one of three methods to determine the average covered lives used for reporting and paying the PCORI fee: (i) the actual count method; (ii) the snapshot method; or (iii) the Form 5500 method. There are special rules that apply for employers offering multiple self-funded plans or an HRA integrated with a fully-insured plan.
- Multiple Self-Funded Plans – If one plan sponsor maintains more than one self-funded health plan with the same plan year, the arrangements can be treated as a single plan for purposes of the fee.
- HRAs – An employer who sponsors an HRA integrated with a fully-insured medical plan is required to pay the fee only with respect to each HRA participant/employee (not required to count dependents or beneficiaries).
For more details on the PCORI fees, see our summary found here.
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