Kilpatrick

Industry News

IRS PCORI Fee Updates

The article tracks the applicable PCORI fee amounts that self-funded employers are required to pay by plan year and the timing for those payments. The fee is used to fund comparative effectiveness research. All health plans that provide Minimum Essential Coverage are subject to the PCORI tax/fee including plans that do not provide Minimum Value.

  • Fully insured plans – paid by health insurer
  • Self-funded plans – paid by employer

Employers pay the fee by July 31 in the calendar year after the end of the applicable plan year using Form 720 (Part II: Applicable self-insured health plans). Employers use one of two counting methods (Actual Count or Snapshot Dates) to determine the average number of lives covered. Most plan administrators provide simplified reporting to assist employers in computing their payment amount. Employers should contact their plan administrator.

  • Actual Count Method – Add total number of members covered for each day of the plan year and divide by the number of days in the plan year.
  • Snapshot Dates – Add total number of members covered on a date or dates during each quarter of the plan year and divide by the number of dates used. The dates used in each quarter must be within three days of the date used in the first quarter.

The table below represents the official fee amounts for published years as well as our own estimates reflecting future inflation under the IRS’s mathematical framework. The applicable fee amount is determined by when the last day of the plan year occurs. The table assumes that the employer uses a standard 12 month plan year (to make it easier to understand) and remember a plan year ends on the day before the next plan year starts. E.g.: A 12-month plan year that begins on Oct 1 ends on Sep 30 the following year.

Plan Years Ending Plan Years Starting
(assumes 12 mo plan yr)
Due Date Fee Amount PMPY Actual or Projected?
Oct–Dec 2012 Oct 2, 2011 – Jan 1, 2012 Jul 31, 2013 $1.00 Actual
Jan–Sep 2013 Jan 2, 2012 – Oct 1, 2012 Jul 31, 2014 $1.00 Actual
Oct–Dec 2013 Oct 2, 2012 – Jan 1, 2013 Jul 31, 2014 $2.00 Actual
Jan–Sep 2014 Jan 2, 2013 – Oct 1, 2013 Jul 31, 2015 $2.00 Actual
Oct–Dec 2014 Oct 2, 2013 – Jan 1, 2014 Jul 31, 2015 $2.08 Actual
Jan–Sep 2015 Jan 2, 2014 – Oct 1, 2014 Jul 31, 2016 $2.08 Actual
Oct–Dec 2015 Oct 2, 2014 – Jan 1, 2015 Jul 31, 2016 $2.17 Actual
Jan–Sep 2016 Jan 2, 2015 – Oct 1, 2015 Jul 31, 2017 $2.17 Actual
Oct–Dec 2016 Oct 2, 2015 – Jan 1, 2016 Jul 31, 2017 $2.26 Actual
Jan–Sep 2017 Jan 2, 2016 – Oct 1, 2016 Jul 31, 2018 $2.26 Actual
Oct–Dec 2017 Oct 2, 2016 – Jan 1, 2017 Jul 31, 2018 $2.36 Projected
Jan–Sep 2018 Jan 2, 2017 – Oct 1, 2017 Jul 31, 2019 $2.36 Projected
Oct–Dec 2018 Oct 2, 2017 – Jan 1, 2018 Jul 31, 2019 $2.47 Projected
Jan–Sep 2019 Jan 2, 2018 – Oct 1, 2018 Jul 31, 2020 $2.47 Projected

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