2021 PCOR Fee Filing Reminder for Self-Insured Plans

The Patient-Centered Outcomes Research (PCOR) fee filing deadline is August 2, 2021, for all self-funded medical plans and

HRAs for plan years ending in 2020. The IRS issued Notice 2020-84 announcing the adjusted fee amount for this year as well as limited transition relief.

The plan years and associated amounts are as follows:

Plan Year Amount of PCOR Fee Payment and Filing Date

February 1, 2019 – January 31, 2020 $2.54/covered life/year August 2, 2021

March 1, 2019 – February 28, 2020 $2.54/covered life/year August 2, 2021

April 1, 2019 – March 31, 2020 $2.54/covered life/year August 2, 2021

May 1, 2019 – April 30, 2020 $2.54/covered life/year August 2, 2021

June 1, 2019 – May 31, 2020 $2.54/covered life/year August 2, 2021

July 1, 2019 – June 30, 2020 $2.54/covered life/year August 2, 2021

August 1, 2019 – July 31, 2020 $2.54/covered life/year August 2, 2021

September 1, 2019 – August 31, 2020 $2.54/covered life/year August 2, 2021

October 1, 2019 – September 30, 2020 $2.54/covered life/year August 2, 2021

November 1, 2019 – October 31, 2020 $2.66/covered life/year August 2, 2021

December 1, 2019 – November 30, 2020 $2.66/covered life/year August 2, 2021

January 1, 2020 – December 31, 2020 $2.66/covered life/year August 2, 2021

This document is designed to highlight various employee benefit matters of general interest to our readers. It is not intended to interpret laws or regulations, or to address specific client situations. You should not act or rely on any information contained herein without seeking the advice of an attorney or tax professional.

Employers with self-funded health plans ending in 2020 should use the 2nd quarter Form 720 to file and pay the PCOR fee by August 2, 2021. The information is reported in

Part II.

Please note that Form 720 is a tax form (not an informational return form such as Form 5500). As such, the employer or an accountant would need to prepare it. Parties other than the plan sponsor, such as third-party administrators cannot report or pay the fee.

Temporary Transition Relief

Generally, there are three established methods a self-funded group health plan may use to determine the average number of covered lives for purposes of calculating the PCOR fee:

• The Actual Count Method,

• The Snapshot Method, and

• The Form 5500 method.

For plan years that end on or after October 1, 2019 and before October 1, 2020, in addition to the established counting methods, a plan may use any reasonable method for calculating the average number of covered lives. This relief has not been extended.