In the wee hours of December 2019, Congress revived the PCORI fee and filing obligations of employer sponsors of self-insured group health plans.
In accordance with the requirements of the Affordable Care Act, employer sponsors of self-insured group health plans were required to file an IRS Form 720 and pay the Patient-Centered Outcomes Research Institute fee (PCORI) by July 31st of the year following last day of the plan year end (e.g., December 31, 2018 Plan Year End; employers should have filed the Form 720 by July 31, 2019).
This requirement was originally scheduled to expire so that most employers would not have to file a Form 720 after 2019. Employers should be aware that this requirement has now been renewed and extended through 2029.
The Further Consolidated Appropriations Act, 2020 signed into law on December 20, 2019 extended the PCORI fee obligation for all plan years ending before October 1, 2029. Accordingly, employers who previously were required to file the Form 720 and pay the PCORI fee should continue to do so on or before each July 31st through 2029 (for calendar year plans). Solely for those employers who sponsor non-calendar year plans with plan years ending between January 1, 2029 and September 30, 2029, the final Form 720 and PCORI fee will be due July 31, 2030.
There was no change to the type of plan subject to the PCORI fee. The government simply extended the original sunset date for the fee from 2019 to 2029.