2017 PCORI Fee Payment Due by July 31, 2018

The Patient-Centered Outcomes Research Institute (PCORI) fee applies to health policy or plan years ending on or after October 1, 2012, and before October 1, 2019. Fees for a year are due by July 31 of the following year.

Actions Needed Now: Sponsors of plans subject to the PCORI fee need to determine the average number of covered lives and file IRS Form 720 by July 31, 2018, with payment of the required fee.

Background: The PCORI is imposed by Code Sections 4375 and 4376, which were added by the Affordable Care Act. For policy and plan years ending after Sept. 30, 2014, and before Oct. 1, 2019, the applicable dollar amount ("ADA") is adjusted to reflect inflation in National Health Expenditures, as determined by the Secretary of Health and Human Services. The fee is calculated by multiplying the ADA by the "average number of covered lives" for the plan year.

PCORI Fee Amount: This chart shows the ADA for plan years ending in 2017.

Plan Year Ending in the Months of:

ADA per Covered Life

Jan. 2017 through Sept. 2017

$2.26

Oct. 2017 through Dec. 2017

$2.39

Plan sponsors can use the actual count method, the snapshot method, or the Form 5500 method to determine the average number of lives covered during a plan year. Calendar year sponsors that elect to use the Form 5500 method for counting lives must file the 2017 Form 5500 by July 31, 2018.

Additional Information: For additional information, please consult the following:

  • Our alert dated October 12, 2017 announced the PCORI fee rates for plan years ending October 1, 2017 through September 30, 2018.
  • Our alerts dated July 6, 2016 and July 2, 2013 provide more information on the methods used to count lives and responses to other FAQs.
  • A copy of the final regulations is at this link.
  • A copy of the IRS form 720 is at this link.

CHEIRON OBSERVATION: Plan sponsors should determine which method of counting covered lives is most advantageous.

Cheiron health consultants can assist with your determination of covered lives and calculation of the PCORI fee due for 2017.

Cheiron is an actuarial consulting firm that provides actuarial and consulting advice. However, we are neither attorneys nor accountants. Accordingly, we do not provide legal services or tax advice.