Each July, employers that had a self-funded medical plan or a health reimbursement arrangement (HRA) with a plan year ending anytime the previous calendar year must file and pay a Patient Centered Outcomes Research fee (PCOR fee) using IRS Form 720 (which has been updated for the 2nd quarter of 2021, so it’s ready for PCOR filings).
This fee had been scheduled to sunset by summer 2020, but it was extended by Congress to be payable another 10 years.
Below is a table of PCOR fees and due dates. Since the fee is based on the plan year END date, we provide some help in the second column to indicate when the respective typical 12-month plan year would have begun as that’s more familiar to most of us. But keep an eye on short plan years, as they must pay the full fee based on the plan year END date.
| Self-funded plan year ends between | For a typical 12-month plan, this means plan year beginning | PCOR Fee | Due Date |
| 1/1/21 and 9/30/21 (inclusive) | Non-CY plan Feb through Oct ’20 | $2.66 | Mon 8/1/22 |
| 10/1/20 and 12/31/20 (inclusive) | Nov ’19, Dec ’19, or CY ’20 | $2.66 | Mon 8/2/21 |
| 1/1/20 and 9/30/20 (inclusive) | Non-CY plan Feb through Oct ’19 | $2.54 | Mon 8/2/21 |
| 10/1/19 and 12/31/19 (inclusive) | Nov ’18, Dec ’18, or CY ’19 | $2.54 | Fri 7/31/20 |
| 1/1/19 and 9/30/19 (inclusive) | Non-CY plan Feb through Oct ’18 | $2.45 | Fri 7/31/20 |
Please let your IMA Benefits team know if you need additional guidance on this fee. We will be securing your average member counts and are happy to walk you through how to complete the Form 720.
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.