Benefits Buzz

2021 PCORI Story

Posted on June 2nd, 2021

The Affordable Care Act (ACA) created a research institute known as the Patient-Centered Outcomes Research Institute (PCORI). The goal of PCORI is to help patients and those who care for them make better-informed decisions about healthcare choices. PCORI is funded in part by fees which are charged to health plans. The following information is designed to help employers understand their upcoming payment obligations.

Fee Amount

The upcoming fee amount depends on when the plan year ended:

  • Plan years ending between January 1, 2020, and September 30, 2020 – $2.54 per covered person
  • Plan years ending between October 1, 2020 and December 31, 2020 – $2.66 per covered person
     

Plan Year Ending Date

This is the last day of the plan year. As an example, a plan that had a July 1, 2019, effective date would have a plan year ending date of June 30, 2020. Alternatively, a plan that had an effective date of January 1, 2020, would have a plan year ending date of December 31, 2020.

Due Date

The fees are due by July 31, 2021, for plan years which ended in 2020.

Fully-Insured Health Plans

The insurance company is responsible for paying the PCORI fee, though most employers with fully-insured health plans are indirectly paying these fees through slightly higher premiums.

Self-Insured Health Plans (including Level-Funded Health Plans)

The employer is responsible for paying the PCORI fee. The fee is determined based on the average number of covered lives in the plan year ending in 2020. An easy way to calculate the average number of covered lives is using a snapshot method. Under this method, an employer picks one day during each quarter of the plan year (e.g., Jan 1, Apr 1, Jul 1, Oct 1), adds the total number of covered lives (including spouses and dependents) for those days, and divides that number by 4.

Non-Integrated HRAs

These are Health Reimbursement Arrangements (HRAs) which are not tied to a traditional group health plan and will generally include Qualified Small Employer HRAs (QSEHRAs), Individual Coverage HRAs (ICHRAs), and certain Retiree HRAs. The PCORI fee for these types of HRAs should be calculated the same way as the self-insured health plans referenced above. However, if the non-integrated HRA only reimburses dental and/or vision expenses, no PCORI fee applies to the HRA.  

Special Rules for Integrated HRAs 

These are HRAs that are only available to employees who are also enrolled in a traditional group health plan. Employers that have a fully insured health plan coupled with an integrated HRA must pay the PCORI fee for the HRA, but they may treat each HRA participant as a single covered life. In other words, the fee generally does not apply to spouses or dependents covered under the HRA. Employers with a self-insured health plan and an integrated HRA may treat the coverage as a single plan assuming both plans have the same plan year.

FSAs

Flexible Spending Accounts (FSAs) are not subject to PCORI fees if they are considered an excepted benefit. To be considered an excepted benefit, employees must be offered a traditional group health plan, and if the employer contributes to the FSA, the employer may not contribute more than (the greater of) $500 or a dollar-for-dollar match of the employee’s contribution.

HSAs

Health Savings Account (HSAs) are not subject to PCORI fees.

Dental & Vision Plans

Stand-alone dental and vision plans are not subject to PCORI fees.

Making Payments

Employers should complete Form 720 to make payments. Form 720 and its associated instructions can be found by clicking here. Be sure to use the form version that has a revision date of June 2021.

Extension of PCORI Fees

At the end of 2019, Congress passed a spending bill with extended the payment of PCORI fees for 10 additional years. PCORI fees will continue to apply to applicable health plans through the fiscal year ending in 2019, with final payments now scheduled to be due in 2030.

 

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