As a reminder, the federal spending bill passed at the end of 2019 included an extension of the Patient-Centered Outcomes Research Institute (PCORI) fees for an additional 10 years (through 2029). Nothing has changed regarding the process or types of plans that are subject to the annual fees.
If you are an employer with a self-funded (including level-funded) health plan, you are responsible for submitting the fees and accompanying IRS Form 720 (Revised for the quarter ending June 2021 https://www.irs.gov/pub/irs-pdf/f720.pdf ). Fully insured health plans or HMOs are responsible for the filing and normally “bake” the fees into your premiums during a year. The PCORI applies to employers of all sizes and is not contingent in any way on a health plan’s “grandfathered” status. The filing/fees are typically due each year by July 31 of the year following the last day of the plan year. For plan years that ended in 2020, the due date will be Aug. 2, 2021 (July 31 falls on a Saturday).
In addition to self-funded health plans, a Health Reimbursement Arrangement (HRA) that is integrated with a fully insured health plan is also subject to the PCORI fee. This is commonly misunderstood. HIPAA-excepted benefit plans (most health FSAs, life, disability, worksite, stand-alone dental, stand-alone vision, HSAs, stop-loss, wellness plans, EAPs and long-term care) are not subject to the PCORI filing or fees.
The IRS indexes the PCORI fee amount per covered life annually. For plan years that end on or after October 1, 2020 and before October 1, 2021, the fee amount is $2.66. This is an increase of $0.12 from the 2019-20 amount.
If you are interested in learning more about alternative funding strategies and/or have questions about the PCORI process, please contact your Johnson Financial Group advisor.