PCOR Fee Indexed in IRS Notice 22-59

The Patient Centered Outcomes Research (PCOR) Institute created by the Affordable Care Act (ACA) was funded by a temporary fee on health plans.  While insurance companies typically take care of reporting and paying this fee for insured plans, an employer with a health reimbursement arrangement or a self-funded health plan is responsible to report and pay this fee each year by July 31 on IRS Form 720.

The fee started out at $1 per employee per year, then increased to $2 the second year, and then has indexed incrementally each year since.  The IRS has announced in Notice 22-59 that the next indexing amount is $3.00.  This essentially means by Monday, July 31, 2023:

• Plan years ending during the first three quarters of 2022 will pay $2.79 per employee, and
• Plan years ending during the fourth quarter of 2022 will pay $3.00 per employee.

It can be a bit confusing how the fee is based on plan year end date (rather than start date) and is not pro-rated for short plan years.  So we provide a chart below to help employers identify the fee and due date for a typical 12-month plan year based on plan year start date.

We provide a more comprehensive overview of how to calculate your PCOR fee each June, a little closer to the July 31 due date.  But please let your IMA Benefits team know if you have any questions.

Self-Funded Plan Year Ends	For a typical 12-month plan, Self-Funded Plan Year Began	PCOR Fee	Due to IRS on Form 720 by
1/1/21 – 9/30/21	Non-CY Feb through Oct 2020	$2.66	Mon 8/1/22
10/1/21 – 12/31/21	Nov’20, Dec’20, or Jan’21	$2.79	Mon 8/1/22
1/1/22 – 9/30/22	Non-CY Feb through Oct 2021	$2.79	Mon 7/31/23
10/1/22 – 12/31/22	Nov’21, Dec’21, or Jan’22	$3.00	Mon 7/31/23
1/1/23 – 9/30/23	Non-CY Feb through Oct 2022	$3.00	Wed 7/31/24

IMA will continue to monitor regulator guidance and offer meaningful, practical, timely information. This material should not be considered as a substitute for legal, tax and/or actuarial advice. Contact the appropriate professional counsel for such matters. These materials are not exhaustive and are subject to possible changes in applicable laws, rules, and regulations and their interpretations.

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