The IRS recently released Notice 2023-70, which outlines the Patient-Centered Research Institute (PCORI) fee rate for plan years ending on or after October 1, 2023 and before October 1, 2024. For these plans, the PCORI fee rate is $3.22 per covered life. For reference, the PCORI fee rate previously announced for plan years ending on or after October 1, 2022, and before October 1, 2023, is $3.00 per covered life.

Plans Subject to the PCORI Fee

Employers who sponsored self-insured group health plans, including level funded plans and health reimbursement arrangements (HRAs), must pay the PCORI fee by July 31, 2024.

Background

The annual PCORI fee was established as part of the Affordable Care Act (ACA) to help fund research regarding the effectiveness of medical treatments so patients, clinicians, purchasers, and policy-makers can make informed health decisions. Insurance carriers are responsible for paying PCORI fees on behalf of fully insured plans and employers are responsible for paying the fee on behalf of self-insured plans.

PCORI Fee Calculations

The PCORI fee is determined by the number of covered lives under each self-insured health plan and the applicable rate per covered life, as summarized below:

PCORI Fee = Rate Per Covered Life x # of Covered Lives Under the Self-Insured Plan

Importantly, the applicable rate per covered life is determined by a plan year’s end date and is increased each year depending on the value of national healthcare expenditures. For the next filing due, employers will pay the fee for self-insured plan years ending in 2023, with rates as follows:

Plan End DatesPCORI Fee Rate
For plan years that END January 2023 through September 2023$3.00 per covered life
For plan years that END October 2023 through December 2023$3.22 per covered life

For more on the PCORI fee, see the IRS PCORI Fee Q&A.

Employer Action Items

  1. Employers that only sponsored fully insured plans in 2023 have no action item (insurance carriers are responsible for paying the fee for these plans).
  2. Employers that sponsored self-insured plans in 2023 (including level funded plans or HRAs) should calculate the PCORI fee, report the fee on IRS Form 720, and pay PCORI fees to the IRS by July 31, 2024.

Additional Resources

The information and materials on this blog are provided for informational purposes only and are not intended to constitute legal or tax advice. Information provided in this blog may not reflect the most current legal developments and may vary by jurisdiction. The content on this blog is for general informational purposes only and does not apply to any particular facts or circumstances. The use of this blog does not in any way establish an attorney-client relationship, nor should any such relationship be implied, and the contents do not constitute legal or tax advice. If you require legal or tax advice, please consult with a licensed attorney or tax professional in your jurisdiction. The contributing authors expressly disclaim all liability to any persons or entities with respect to any action or inaction based on the contents of this blog. © 2023 Sequoia Consulting Group. All Rights Reserved.

Diane Cross — Diane is a Client Compliance Consultant for Sequoia, where she works with our clients to optimize and streamline benefits compliance. In her free time, Diane enjoys spending time with her family, live music, and cycling.