Employers who sponsor self-insured plans (including level-funded) must report and pay the annual PCOR fee. The filing is due no later than July 31 of the calendar year immediately following the last day of the plan year to which the fee applies. Employers who experience a short plan year or change funding type midyear may be confused about which plan years are due.
If a medical plan experiences a short-plan year, the employer will need to look at the last day of the plan year(s) to determine relevant filings. An example is an employer that historically had a July 1 plan year but changed to a calendar year plan as of January 1, 2026. The employer would need to report and pay the PCOR fee for the regular plan year July 1, 2024, to June 30, 2025, and also the short year July 1, 2025, to December 2025. Both filings would be due July 31, 2026. The plan year that began January 1, 2026, would not be due until 2027.
Similarly, an employer could change plan funding midyear, although this is not a common occurrence. If such a change occurs, the employer would be responsible for reporting and paying the months within the plan year that were self-insured, and the carrier would pay and report the months that were fully insured. An example is an employer that sponsored a fully insured plan January 1, 2025, to June 30, 2025, but switched to self-insuring the plan for the remainder of the year (July 1, 2025, to December 31, 2025). The carrier would report and pay the PCOR fee for January 1, 2025, to June 30, 2025, and the employer is responsible for July 1, 2025, to December 31, 2025.
While many employers do not experience these types of midyear changes, it is important to understand the PCOR fee reporting rules if such a change occurs. For additional information regarding PCOR filings, including a chart depicting filing due dates based on plan year end date, please ask your broker or consultant for a copy of the NFP publication PCOR Fees: A Guide for Employers.