Plan sponsors of self-funded plans, including Individual Health Reimbursement Arrangement (ICHRA), take note: the annual PCORI filing and fee payment are due August 2, 2021 for plans that ended in 2020. Normally, the fee is due on July 31 of the following year, however, this year the due date has been extended to August 2 because July 31 falls on a Saturday.

PCORI in a Nutshell

The Affordable Care Act imposes a fee on plan sponsors (usually the employer) of applicable self-insured health plans to help fund the Patient-Centered Outcomes Research Institute (PCORI). All HRAs are considered self-insured plans, including ICHRAs. The fee, required to be reported only once a year on the second quarter Form 720, Quarterly Federal Excise Tax Return and paid by its due date, July 31, is based on the average number of lives covered under the policy or plan.

The fee applies to policy or plan years ending on or after October 1, 2012, and before October 1, 2029. The PCORI fee is filed using Form 720. Although Form 720 is a quarterly return, for PCORI, Form 720 is filed annually only, by July 31 (note that for plans that ended in 2020 the deadline is extended to August 2).

For additional information about the PCORI fee filing, please go to Patient-Centered Outcomes Research Institute.  There you will find Form 720 and instructions for filing Form 720.