Health Care Reform Fees - Special Rules for HRAs
To cover the cost of some of its reforms, the Affordable Care Act (ACA) imposes a number of fees on health insurance issuers and sponsors of self-insured health plans. These fees include:
- Patient-Centered Outcomes Research Institute fees (PCORI fees); and
- Reinsurance fees.
Both of these fees are calculated based on the average number of covered lives under the plan. For employers that maintain multiple self-insured arrangements, such as a health reimbursement arrangement (HRA) in addition to major medical coverage, this could have resulted in having to pay each fee twice for each covered life, effectively doubling the amount of these fees. To avoid this result, the Internal Revenue Service (IRS) developed special rules for applying PCORI fees and reinsurance fees to HRAs.