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PCOR Fee Questions? Here’s a Quick Start.

Dear MGIS Client,
Businesses of all sizes and types are preparing for – and bracing for – the phased impacts of the Affordable Care Act (ACA), which are fast closing in.

Many clients have asked for clarification on potential ACA-related PCOR fees that may be assessed on their CDH accounts under the new healthcare act. While we do not provide legal opinion on the application of the law in your business, we have developed the following chart that may provide quick, high-level guidance in determining what the PCOR impacts may be on your organization.

PCOR Fee Guidelines
Consumer-Directed Healthcare Plans
Plan PCOR Fee Requirement
Health Flexible Spending Arrangement (FSA) No, as long as FSA is a HIPAA-excepted benefit.
Health Savings Account (HSA) No. The HDHP is covered as major medical.
Health Reimbursement Arrangement (HRA) – Stand Alone Yes
Health Reimbursement Arrangement (HRA) – Integrated Yes. When integrated with a self-insured plan of the same sponsor, PCOR fee is based on a combined life count. When integrated with an insured plan, PCOR fee is determined separately as if it was a stand-alone HRA.
COBRA coverage Yes
Dependent Care Account (DCA) No
Commuter Benefit Account (CBA) No

This chart contains information intended to provide general guidelines to assist clients in determining their obligations under the Affordable Care Act. It is not intended to replace the guidance of legal counsel. Please consult your attorney or tax advisor regarding application of the law to your specific company and circumstances.

CDH accounts will continue to be an attractive and valuable benefit for employers as we enter this new healthcare landscape. We are committed to keeping you at the leading edge of plans and benefits.

If you have specific PCOR-related questions, we encourage you to consult your tax advisor. As always, your MGIS account representative is ready to assist with plan design and administration matters.

Best Regards,

Noelle Lundberg
CDH- Senior Sales Executive
Medical Group Insurance Services, Inc.

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