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PCORI Fees Due to IRS No Later Than July 31, 2025

June 16, 2025/in Carrier, Compliance, Cornerstone Updates, Employee Benefits, Legislation/by Cornerstone

Fees to fund the Patient-Centered Outcomes Research Institute (PCORI) are due to the IRS no later than July 31, 2025, from employers who sponsor certain self-insured health plans, such as level funded and Health Reimbursement Arrangements (HRAs), that are not treated as excepted benefits.

How to Pay PCORI Fees

Employers that sponsor certain self-insured health plans (level funded) must report and pay the required PCORI fees via IRS Form 720 along with HRA plans, Quarterly Federal Excise Tax Return. Complete Part II, line 133. Employers should note “2nd Quarter” on the 720 form.

Click here to access the 720 form.

Click here to review instructions for Form 720.

The fee applies to each Plan year that ends after October 1, 2012, and before October 1, 2029. “Plan year” refers to the plan year for your Level Funded Medical Plans or an HRA plan. Generally the plan year and the coverage period are the same. As an example, if your HRA benefit resets each January 1, your HRA plan year and your coverage period are generally a calendar year and end December 31.

Plan Year Ending Date

Fee

October 1, 2024 – September 30, 2025 $3.47
October 1, 2023 – September 30, 2024 $3.22

There are three available methods that can be used to determine the average number of lives covered under a plan for the policy year. For an HRA plan it is acceptable to use the number of subscribers only. The most commonly used method for determining the fee for your Level Funded plan is the “Snapshot Method”.

  1. Actual Count Method: A plan sponsor may determine the average number of lives covered under a plan for a plan year by adding the totals of lives covered for each day of the play year and dividing that total by the total number of days in the plan year.
  2. Snapshot Method: A plan sponsor may determine the average number of lives covered under an applicable self-insured health plan for a plan year based on 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 dividing that total by the number of dates on which a count was made.
  3. Form 5500 Method: An eligible plan sponsor may determine the average number of lives covered under a plan for a plan year based on 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.

Payments should be made payable to the U.S. Treasury and sent by July 31, 2024, to the address below:

Department of the Treasury
Internal Revenue Service
Ogden, UT 84201-0009

The following documents accompany this notice:

  • The Form 720
  • Instructions for the Form 720
  • Patient-Centered Outreach Research Institute Filing Due Dates and Applicable Rates Flier

Tools to Assist you by Carrier

**Anthem OH SOCA MEWA, Anthem KY Chamber Advantage, Anthem IN Chamber Health Alliance, MMO COSE MEWA, and UHC MEWA have built the PCORI fees into the premiums, therefore, groups won’t need to file and pay additional fees.

Aetna Funding Advantage (New Change This Year!)

The employer group is required to complete and file the IRS Form 720. New this year, Aetna will be sending groups a membership report in June and providing a PCORI calculator to aide groups in determining the amount due in their 2024 PCORI filing. Please wait until July 1st before requesting copies of this report, from your Cornerstone account manager, should your client not receive the email message as they will not be available prior to this date. These reports unfortunately won’t be available online in Aetna’s Producer World.

Anthem Balance Funded (Level Funded)

The employer group is required to complete and file the IRS Form 720. Membership reporting will be included on claim reports, which are available upon request from Anthem. Please reach out to your Cornerstone account manager for assistance.

Allstate

The PCORI notification went out to all groups the first week of June.

Information regarding PCORI fees is in the notification below. The group must log onto the Allied Web, www.alliedbenefit.com:

What Plan Sponsors Need to Do: Allied believes that the snapshot count method is the most suitable approach to determine the average number of medical lives during the applicable plan year. To determine the average number of medical lives, please take the following steps:

  1. Log into your Employer Portal account via alliedbenefit.com.
  2. From the “Web Reports” page, run four (4) different census reports, one for each of the last four quarters on the same date (i.e., the first of the month, the fifteenth of the month, etc.).
  3. Each Allied census report will provide you with the total number of covered medical lives for the date requested on the census report.
  4. Add up the total number of covered lives from each of these reports and divide that number by four to determine the total number of average lives that should be listed on FORM 720.

Humana Level Funded

Humana will provide a snapshot report that shows monthly membership which can be obtained by calling the service team at 800-592-3005. Several groups will need to file their 2024 form using the partial months covered with Humana prior to their market exit. Please see a refresh of those timeframes below:

  • KY – Started non-renewals on November 1, 2023 and most groups were termed on or before September 30, 2024.
  • IN – Started non-renewal for ASO, LFP, and 51+ Fully Insured on November 1, 2023.
  • IN Small group 1 to 5 – Started non-renewal January 1, 2024.  All groups termed on or before December 31, 2024.
  • OH – Started non-renewals on December 1, 2023.  All groups termed on or before October 31, 2024.

Click here to review the instructions.

Medical Mutual of Ohio Balanced Solutions (Level Funded)

The employer group is required to complete and file the IRS Form 720. Membership reporting will be included on claim reports, which are available quarterly upon request from MMO. Please reach out to your Cornerstone account manager for assistance.

The Christ Hospital Plan

The employer group is required to complete and file the IRS Form 720. PCORI membership reports will be available on the Key Benefit Administrators portal so please reach out your Cornerstone account manager for assistance.

Click here to learn more (PCORI Reports listed under forms and documents)

Trustmark

The employer group is required to file the IRS Form 720. Trustmark will send the group, with a copy to the broker, a PCORI membership report. If the group hasn’t received their report, please reach out to your Cornerstone account manager for assistance.

UnitedHealthcare Level Funded

The employer group is required to complete and file the IRS Form 720. UHC mailed a PCORI fee membership report to the employer portal mid June. Groups may access their reports by logging on to the UHCeservices.com portal:

  • Click on “Reports”
  • Click on “Level Funded Reports”
  • “PCORI” should then be at the top when available
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