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Form 720 and PCORI fee FAQs

Written by: Chase Charaba
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Published on June 30, 2022.

If you’re a small business owner, you may have heard of the acronym PCORI and the fees that come with it. But, what is PCORI, and how does it apply to your organization?

The Affordable Care Act (ACA) introduced a fee paid by sponsors of self-insured health plans to fund the Patient-Centered Outcomes Research Institute (PCORI).

PCORI is an independent organization created by the ACA that conducts research to help healthcare consumers make better decisions for their specific needs and outcomes and support clinical effectiveness.

Employers offering a self-insured medical reimbursement health plan, such as health reimbursement arrangements (HRAs), must pay this fee by July 31 each year (or August 1 if the date falls on a weekend) via Form 7201.

This fee was initially set to expire in 2019 but has been extended through September 30, 20292, due to the Further Consolidated Appropriations Act of 20203.

Looking to provide your employees with a compliant health benefit? Read our free guide on HRAs

Who owes a PCORI fee?

Specified health insurance policies subject to PCORI fees are generally prepaid health coverage arrangements with fixed premiums for accident or health coverage.

If your company offers a self-insured health plan, such as an HRA, you will need to pay the PCORI fee.

However, an integrated HRA is not subject to PCORI4 if it’s offered alongside a self-insured plan from the same plan sponsor. In this case, the HRA and medical plan are considered a single plan for PCORI fee.

An HRA that only covers dental and vision expenses is also exempt from the PCORI fee.

PCORI fees apply to organizations that offer different benefits, including:

Which plans are exempt from the PCORI fee?

Some benefits, such as flexible spending accounts (FSAs), health savings accounts (HSAs), and other excepted benefits, aren't subject to the fees.

Health plans exempt from the PCORI fee include:

  • Government programs
    • Including Medicare, Medicaid, Children's Health Insurance Program (CHIP)
  • Insurance policies that only provide excepted benefits, such as vision or dental
  • Wellness programs (as long as the program doesn't provide significant medical care or treatment benefits)
  • Policies that solely cover international employees
  • Archer medical savings accounts (MSAs)
  • Hospital indemnity
  • Accident-only coverage
  • Workers' compensation

How much is the PCORI fee?

For plan years ending on or before September 30, 2021, the fee is $2.66 per covered life. For plans ending on or after October 1, 2022, the fee is $2.79 per covered life.

The amount is adjusted for inflation every year by the Secretary of Health and Human Services5.

What is IRS Form 720?

Form 720, known as the Quarterly Federal Excise Tax Return6, is used by organizations to report any federal excise taxes collected.

This includes a variety of tax categories and fees, such as:

  • Environmental taxes
  • Communications and air transportation taxes
  • Fuel taxes
  • Retail tax for trucks, trailers, and semitrailer bodies
  • Ship passenger taxes
  • Other excise taxes
  • Foreign insurance taxes
  • Manufacturers taxes
  • PCORI fees for specified health insurance policies and applicable self-insured health plans

Does my business need to submit IRS Form 720?

If you owe a PCORI fee, it must be paid using IRS Form 720 by July 31 following the last day of the plan year. For self-insured health plans, see Part II, IRS No. 133 (b) of the form. If your business does not owe a PCORI fee, IRS Form 720 doesn't need to be completed.

If you currently file Form 720, you will pay the fee with your second quarter return. If you don't regularly file Form 720, you only need to file the form once, during the second quarter with your return. You don't need to file a Form 720 every quarter.

How to calculate the PCORI "number of lives"

According to Form 720 instructions, there are three ways to count the number of lives for plan years.

Here's what the instructions state for calculating the number of lives:

  • The actual count method: Add the totals of lives covered for each day of the plan year and divide that total by the total number of days in the plan year
  • The snapshot method: Take the total number of lives covered on one date (or more dates if an equal number of dates is used in each quarter) during the first, second, or third month of each quarter and divide that total by the number of dates on which you made a count
  • Form 5500 Method: Take the number of participants reported on the Form 5500, Annual Return/Report of Employee Benefit Plan, or the Form 5500-SF, Short Form Annual Return/Report of Small Employee Benefit Plan

Additionally, there are special rules for calculating covered lives if you offer multiple self-funded plans or an integrated HRA from a medical insurance provider.

For multiple self-funded plans, they can be treated as a single plan, with each unique covered life only being counted once.

You can view detailed information about “lives covered” in the final regulations7 document.

Does COBRA coverage to retirees or former employees count as "lives" covered?

Yes. You must count COBRA-covered individuals and dependents in the total number of lives for your benefit.

How to complete Form 720

New to filling out Form 720? We’ve compiled a new examples. Below, the company plan covered an average of three participants and had a plan year that ended on December 31, 2021.

This section is included for informational purposes only. You should consult with your tax adviser to ensure proper compliance with the law.

Step 1: Complete company information header

In the header, the quarter ending date will be June 30, 2022, as you’re filing the form for Q2. Don’t check Final return unless your organization is going out of business or you aren’t required to file Form 720 in future quarters.

Step 2: Complete Part II, line 133(c) or (d)

Complete line 133(c) if your organization’s plan year ended before October 1, 2021. Complete line 133(d) if the plan year ended on or after October 1, 2021 (this is the case with most plans).

IRS7201

Step 3: Complete Part III lines 3 and 10, sign and date

IRS7202

Step 4: Complete the payment voucher

IRS7203

Step 5: Send the completed form, payment voucher, and check to the IRS

You’ll send Form 720 to the IRS in Ogden, Utah.

Send to:

Department of the Treasury

Internal Revenue Service

Ogden, UT 84201-0009

Conclusion

For applicable employers, the deadline to submit IRS Form 720 and pay PCORI fees is July 31. You should always consult a tax professional to ensure you're filling out your form and paying the fees correctly.

If you want a compliant, tax-advantaged health benefit for your employees, PeopleKeep can help! Our HRA administration software makes it easy to set up and manage your health benefit in minutes.

Schedule a call with a personalized benefits advisor today to learn how an HRA can help your organization grow

This blog article was originally published on August 4, 2020. It was last updated on June 30, 2022.

1. https://www.irs.gov/forms-pubs/about-form-720

2. https://www.irs.gov/newsroom/patient-centered-outcomes-research-institute-fee

3. https://www.congress.gov/bill/116th-congress/house-bill/1865

4. https://www.irs.gov/newsroom/application-of-the-patient-centered-outcomes-research-trust-fund-fee-to-common-types-of-health-coverage-or-arrangements

5. https://www.irs.gov/affordable-care-act/patient-centered-outcomes-research-trust-fund-fee-questions-and-answers

6. https://www.irs.gov/pub/irs-pdf/i720.pdf

7. https://www.govinfo.gov/content/pkg/FR-2012-12-06/pdf/2012-29325.pdf

Originally published on June 30, 2022. Last updated June 30, 2022.
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