IRS Guidance Provides Helpful Clarification for HDHPs
November 13, 2024New Jersey Releases 2025 Disability and Family Leave Amounts
December 23, 2024On December 3, 2024, the IRS released Notice 2024-83, announcing that the adjusted applicable dollar amount used to determine the PCOR fee for plan years ending on or after October 1, 2024, and before October 1, 2025, is $3.47.
The PCOR filing deadline is July 31, 2025, for all self-funded medical plans (including level-funded) and some HRAs (including ICHRAs) for plan years (including short plan years) ending in 2024. Carriers are responsible for paying the fee for insured policies.
Employer Action
For now, no action by employers with self-funded health plans (or an HRA) is required. We will send a reminder in mid-2025 of the fee and additional information for filing and paying the PCOR fee with the IRS.
It should be noted that we have seen increased enforcement activity from the IRS around missing PCOR fees. Specifically, the IRS is issuing CP161 notices to employers who appear to have missed a prior year PCOR fee filing, requesting payment (including interest and penalties).