PCORI Fee Worksheet

Overview

Starting from the plan years ending on or after October 1, 2012, until October 1, 2029, health insurance issuers and self-funded health plan sponsors are obligated to pay an excise tax referred to as the "PCORI fee." This fee is intended to finance the Patient Centered Outcomes Research Institute. It is calculated based on the average number of individuals covered by the plan, including employees, dependents, COBRA participants, and retirees, and must be paid by July 31 following the end of each relevant year.

Health reimbursement arrangements (HRAs) are categorized as self-funded health plans and are subject to the PCORI fee. However, there are specific rules that apply to HRAs when determining the fee:

• If the plan sponsor also maintains a self-funded medical plan with the same plan year, the medical plan and HRA may be treated as a single plan for the PCORI fee calculation. Nevertheless, if the medical plan is fully insured, the medical plan and HRA must be treated as separate plans, with the insurer paying the fee for the medical plan and the employer/plan sponsor paying the fee for the HRA.
• For counting covered lives in HRAs, only employees are considered, and spouses/dependents are excluded. Different methods are available to determine the fee for HRAs treated as separate plans from a fully insured medical plan, which will be explained below.

Methods for calculating the fee:

The following information pertains exclusively to HRAs that must be treated as separate plans from a fully insured medical plan.

Provided below is a worksheet using the methods specified in the PCORI fee final regulations, adjusted as applicable for HRAs treated as separate plans from a fully insured medical plan. HRA plan sponsors must select one method to be used for the entire plan year, although a different method may be chosen for subsequent plan years.

For plan years commencing before July 11, 2012, and concluding on or after October 1, 2012, the average number of covered employees can be determined using "any reasonable method." Otherwise, one of the following methods must be employed:

1. Actual Count Method
2. Snapshot Method
3. Form 5500 Method

* Use the PCORI Fee for Self-Funded Plans worksheet to calculate the PCORI fee for self-funded plans and HRAs that may be treated as a single plan.

** Starting in 2014, health insurance issuers and plan sponsors of self-funded plans must also make contributions to a temporary reinsurance program, which will also be based on the number of covered lives. Proposed regulations indicate that the methods to calculate the temporary reinsurance program fee will be similar to those required for the PCORI fee. Different methods may be used to determine the PCORI fee and the temporary reinsurance program fee. HRAs that are integrated with self-funded or fully-insured medical coverage are not subject to the temporary reinsurance program fee.