Skip to content
Baldwin Bulletin

REMINDER – PCORI Fees Due July 31, 2024

The Baldwin Group
Updated: June 7, 2024
1 minute read

The Patient-Centered Outcomes Research Institute (“PCORI”) fee initially applied from 2012 to 2019; however, in December 2019, the Further Consolidated Appropriations Act extended the fee to 2029. Consequently, employers who sponsor self-insured medical plans, including health reimbursement arrangements (“HRAs”) which are integrated with medical insurance, must continue to pay the fee through year 2029.

Employer Action Items

There are three possible methods applicable for plan years ending in 2023:

  • Actual count method: Covered lives are calculated on each day of the plan year, and the result is averaged over the total number of days in the plan year.
  • Snapshot count method: The number of lives covered on a date equals the actual number of lives on a specified date. To compute, add the total number of lives covered on a certain date during the first three quarters of the benefit year and divide that total by the number of dates on which a count was made. For this purpose, the same months must be utilized for each quarter and the date utilized for the second and third quarters must fall within the same week of the quarter as the corresponding date utilized for the first quarter.
  • Form 5500 method: For health plans that are required to file IRS Form 5500 (those with 100 or more participants), alternative methods of counting are available depending on whether dependent coverage is offered. Form 5500 must be filed by July 31 to use this option. The additional details on using this method are beyond the scope of this summary.

Note: The snapshot count method is generally recommended. However, consult with your tax advisor for more information and to determine which method is best for your organization.


The fee, in the form of a federal excise tax, applies to all such plans and there are no exceptions for smaller employers. However, most health flexible spending accounts (“FSAs”) offered in conjunction with medical insurance are exempt from the PCORI fee. A plan sponsor is also able to treat multiple self-insured plans with the same plan year as a single plan for reporting and payment purposes.

 For More Information

For further information, including links to the final PCORI regulations, questions and answers regarding the PCORI Fee, a chart depicting the types of insurance coverage subject to the fee, and the Form 720, along with instructions, please visit the IRS website at

Related Insights

Stay in the know

Our experts monitor your industry and global events to provide meaningful insights and help break down what you need to know, potential impacts, and how you should respond.

Baldwin Bulletin
Question of the Month
Question: Can a company shareholder with >2% shares in an S Corporation be an HSA-Eligible Individual?  IRS Publication 969 appears...
Baldwin Bulletin
HHS Finalizes Rule to Strengthen Reproductive Health Care Privacy
On April 22, 2024, the Department of Health and Human Services (“HHS”) issued a final rule to modify certain provisions...
Baldwin Bulletin
Change Healthcare, a U.S. Healthcare Company, is Confirmed as a Cyberattack
On February 21, 2024, UnitedHealth Group disclosed that one of its companies, Change Healthcare, experienced a cyberattack. This was a...
Baldwin Bulletin
Navigating Healthcare Costs: Update on Advanced Explanation of Benefits (AEOB)
On April 23, 2024, the Centers for Medicare & Medicaid Services (“CMS”) provided a status update on the implementation of...
Baldwin Bulletin
DOL Rescinds 2018 Final Rule on Association Health Plans
The Department of Labor (“DOL”) rescinded their 2018 rule entitled ‘‘Definition of Employer Under Section 3(5) of ERISA—Association Health Plans’’...
Let's make it possible

Partner with us to build solutions that align with your business, individual, or employee needs and open new possibilities for your future.

Connect with us