ACA News & Publications

ACA Pathways: Attention Self-insured Plan Sponsors: PCORI Fee Payment Deadline Fast Approaching

July 10, 2014

The Affordable Care Act (ACA) contains several temporary annual fees and payments that apply to group health plans and insurers. One such fee, the annual Patient-Centered Outcomes Research Institute (PCORI) Fee is due by July 31, 2014. The PCORI Fee is imposed on plan sponsors of applicable self-insured health plans and issuers of specified health insurance policies. This means that employers who sponsor self-funded plans are responsible for paying this fee, as are insurers of most fully insured policies.

PCORI is intended to help patients, clinicians, payers and the public make informed health decisions by advancing comparative effectiveness research. The research is to be funded, in part, by fees paid by health insurance issuers (including HMOs) and sponsors of self-insured health plans. The PCORI Fee first became effective beginning with plan years ending on or after October 1, 2012 (Generally for plan years beginning November 1, 2011 and ending

October 31, 2012), and will be assessed annually for seven years. The research fees do not apply for plan years ending on or after October 1, 2019. For calendar year plans, the research fees will be effective for the 2012 through 2018 plan years.


The PCORI Fee is considered an excise tax that must be reported on Internal Revenue Service (IRS) Form 720 for the second quarter reporting period. It is due by July 31 of the year following the last day of the plan year being reported on. Payment is to be remitted along with the Form 720 filing and the amount will vary depending on the plan year. PCORI Fee payments were first due July 31, 2013 for plan years ending on or after October 1, 2012 and before January 1, 2013. The July 31, 2014 deadline will be the first year being reported on for many plans, including most plans with non-calendar year plan years.

Not all self-insured plans are subject to the PCORI Fee. Fees are not assessed against most healthcare flexible spending accounts (unless they do not meet the requirements for being an excepted benefit under the ACA), as well as employee assistance, disease management, and wellness programs not providing significant medical care benefits, and plans covering primarily employees working outside the United States. Furthermore, a plan sponsor is able to treat multiple self-insured plans with the same plan year as a single plan for reporting and payment purposes. For example, a plan sponsor with a self-insured plan providing major medical benefits and a separate self-insured plan with the same plan year that provides prescription drug coverage may be considered as a single plan so that the same covered life under each plan is counted only once.

Determining The Fee Amount

The following table depicts the fee amount payable by the July 31, 2014 filing and payment deadline:

Plan Year Ending Fee Amount
January 31, 2013 $1 per avg. # covered lives
February 28, 2013 $1 per avg. # covered lives
March 31,2013 $1 per avg. # covered lives
April 30, 2013 $1 per avg. # covered lives
May 31, 2013 $1 per avg. # covered lives
June 30, 2013 $1 per avg. # covered lives
July 31, 2013 $1 per avg. # covered lives
August 31, 2013 $1 per avg. # covered lives
September 30, 2013 $1 per avg. # covered lives
October 31, 2013 $2 per avg. # covered lives
November 30, 2013 $2 per avg. # covered lives
December 31, 2013 (calendar year plans) $2 per avg. # covered lives

Plan sponsors of self-insured plans may use one of three methodologies for determining the average number of covered lives under the plan for the plan year:

  1. The Actual Count Method. Under the Actual Count Method, the average number of covered lives is determined by adding the totals of lives covered each day of the plan year and dividing by 365 or 366, as applicable.
  2. The Snapshot Method. Under the Snapshot Method, the average number of covered lives is based on the total number of covered lives on a particular date (or dates) in the first, second, or third month of each quarter, divided by the number of dates on which the count was made. An equal number of dates must be used for each quarter, and each date used must be within three days of the corresponding date in the other quarters under this method.
  3. The Form 5500 Method. Under the Form 5500 Method, for a plan that offers both self-only coverage and dependent (family) coverage, the average number of covered lives is based on the total number of participants covered at the beginning and the end of the plan year divided by two, per the Form 5500 (or Form 5500-SF) that was filed for the plan no later than July 31st following the end of the plan year being reported on.

For further information, including links to the final PCORI regulations, questions and answers regarding the PCORI Fee, a chart depicting the types of insurance coverage subject to the fee, and the Form 720, along with instructions, please visit the IRS website at

For More Information
For more information about this ACA Pathways or about any other health care reform-related provisions, please contact your Burnham Benefits consultant or Burnham Benefits at:

Burnham Benefits

This ACA Pathways is not intended to be exhaustive nor should any discussion or opinions be construed as legal advice. Readers should contact legal counsel for legal advice. The information contained in this ACA Pathways includes emerging health care news from a limited perspective and does not encompass all views. The information was selected from a wide range of sources selected on the basis of their potential impact on employers and/or their employee benefit plans. For more information, please contact Burnham Benefits.

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