Form 8963 Guide – Net Premiums and 2020 Fee

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A health insurer cleaning up old records during diligence will sometimes find that Form 8963 still matters years after the fee itself went away. The fee was repealed for calendar years after December 31, 2020, so no new assessment runs for 2021 and later, but a covered entity can still face historical corrections covering fee years 2014, 2015, 2016, 2018, and 2020.

What catches people is that the figures on this form were statutorily public, not confidential return information. A small classification slip on net premiums written, or a missed 50% exclusion for a 501(c)(3), (4), (26), or (29) entity, sits in the open record. When you reopen one of these files, the workpapers and the filed numbers need to reconcile cleanly.

Key Takeaways

• Form 8963 is the Report of Health Insurance Provider Information, used by covered entities to report net premiums written for the data year.
• The latest form is Form 8963 (Rev. January 2020), OMB No. 1545-2249, reporting year 2020. It was filed to set each covered entity’s share of the annual health insurance providers fee.
• Part I identifies the filer (single-person covered entity, agent of an affiliated group, or other), and Schedule A lists single-person covered entity or controlled group member information including EIN, NAIC code, direct premiums written, and MLR rebates.
• A 50% exclusion applies for 501(c)(3), (4), (26), or (29) entities, entered with the code section and premiums on Schedule A.
• The fee applied through the 2020 fee year. Congress repealed it for calendar years beginning after December 31, 2020, so there is no new assessment for 2021 and later.
• Form 8963 information is statutorily public, not confidential return information, so filed figures and your workpapers should reconcile.

What Form 8963 Was For, In Plain English

You used Form 8963 to tell the IRS your net premiums written for U.S. health risks for the data year, which was the calendar year before the fee year. The IRS pooled everyone’s numbers, calculated each filer’s share of the industry total, then multiplied your share by the annual applicable amount to set your fee. For 2020, that applicable amount was 15,522,820,037.

Historical reminder, the fee applied through the 2020 fee year. Congress repealed it for calendar years beginning after December 31, 2020, so there is no new assessment for 2021 and later. Use this content to audit past filings, respond to notices, or document corrections, not to plan current payments.

The Core Definition You Cannot Get Wrong

Start at the source. Net premiums written means premiums written, including reinsurance premiums written, reduced by reinsurance ceded, and reduced by ceding commissions and MLR rebates. Include assumption reinsurance. Exclude indemnity reinsurance, and do not reduce for indemnity reinsurance ceded. Keep a short memo in your files that explains how you applied this. It saves hours later.

Tip, tie amounts to NAIC SHCE or MLR filings where possible, and keep a reconciliation if you used multiple sources. The 2020 instructions allow for that approach.

Why “Public” Matters Here

Form 8963 data can be open for inspection, and unlike most tax returns it is not confidential return information protected by IRC §6103, it is statutorily public under §9010(g)(4). That means a mismatch between what you filed and what sits in your workpapers is not just a processing hiccup, it is a reputational risk. Build your review with that in mind, especially for controlled groups that aggregate several entities.

How The IRS Calculated The Fee

Here is the simple version you can share with a partner or a client contact.

• You reported net premiums written on Form 8963 for the data year.
• The IRS added up all filers’ net premiums written.
• Your percentage of the total set your share of the applicable amount.
• The IRS sent a preliminary calculation, you had a window to correct errors, and the final fee was due by September 30 of the fee year.

For 2020, the applicable amount was 15,522,820,037. Since the fee was repealed for fee years after 2020, that was the last cycle.

Timeline, What Was Typical

• File Form 8963 by April 15 of the fee year.
• Expect the IRS preliminary notice by June 15.
• If needed, submit a corrected report by July 15.
• Pay the final fee by September 30. These milestones come straight from IRS bulletins on the fee program and help you set expectations when you are reviewing an old file or building a response plan.

Short quote to remember, “Any Form 8963 reporting more than 25 million in net premiums written must be filed electronically.” Keep that rule in your checklist for historical corrections.

Who Filed, And When Your Group Filed As One

If you provided health insurance for U.S. health risks in the data year, you were generally a covered entity for fee purposes. That included health insurance issuers, HMOs, insurers under subchapter L, certain tax‑exempt insurers, Medicare Advantage or Part D organizations, Medicaid insurers, and some MEWAs.

If you were in a controlled group treated as a single employer, the whole group filed as one covered entity through a designated entity, not a separate Form 8963 per member. You listed members and their net premiums written on Schedule A, collected consents, and kept those on file. It is common to find documentation gaps here when teams change. If you are doing a cleanup, confirm year‑end group membership, eliminate intra‑group double counts, and make sure the signer had authority.

Quick Table, Who Filed What

Situation	What you filed	Notes
Single‑person covered entity	One Form 8963, your Schedule A line	Confirm EIN and NAIC codes match source files.
Controlled group	One Form 8963 by designated entity, full Schedule A	Collect and retain member consents for Schedule A.
Over 25M in net premiums	Electronic filing required	Once one filing for that fee year is e‑filed, all subsequent filings for that year must be e‑filed.

Getting Net Premiums Written Right, With Examples

First, confirm the scope. Only count U.S. health risks, which means U.S. citizens, U.S. residents under section 7701(b)(1)(A), or people located in the United States during the relevant period. If you are reviewing an older file with expatriate plans or multi‑state programs, cross check how the team drew the lines.

Next, apply the mechanics that trip people up:

• Assumption reinsurance. Include it in direct premiums written, then deduct assumption reinsurance ceded.
• Indemnity reinsurance. Do not include indemnity reinsurance written in direct premiums written, and do not deduct indemnity reinsurance ceded.
• MLR rebates and ceding commissions. Reduce for both.
• Source tie‑outs. Use NAIC SHCE and MLR forms, then reconcile any differences and keep that memo with your schedules.

Think of assumption reinsurance like a full hand‑off of the policy and risk, and indemnity reinsurance like backup. Only the full hand‑off flows through your net premiums written here.

A Mini Walkthrough

• Start with direct premiums written for U.S. health risks from SHCE Part 2 and the MLR form.
• Subtract MLR rebates and ceding commissions for the data year.
• Adjust for reinsurance. Add assumption reinsurance written to direct premiums, subtract assumption reinsurance ceded, ignore indemnity reinsurance for both inclusion and deduction.
• For controlled groups, aggregate across members, then scrub intra‑group reinsurance that would double count.

If your total feels off, pull three quick diagnostics. One, scan for indemnity reinsurance deductions that should not be there. Two, confirm that dental or vision stand‑alone amounts were handled per the instructions. Three, tie to last year’s data to spot discontinuities that need an explanation.

Filing Mechanics You Still Need For Historical Work

Even though the fee ended after 2020, you may still prepare a corrected report, respond to an IRS letter, or reconstruct a file for diligence. Here is the process recap that matters now.

• Due date. April 15 of the fee year, for example April 15, 2020 for the 2020 fee year. Keep that date in your narrative when you explain why a correction is late or timely.
• E‑file rule. If you reported more than 25 million in net premiums written, you had to e‑file, and any additional filings for that fee year also had to be electronic. That includes corrections.
• Paper and fax, 2020 only. For 2020, the IRS allowed paper filing for entities under the threshold and offered a limited fax option with Form 8453‑R. This was a one‑year accommodation, so make sure your internal playbook labels it as historical.
• Address. Paper mail went to Internal Revenue Service, 1973 Rulon White Blvd., Mail Stop 4916 IPF, Ogden, UT 84201‑0051. Use a flat envelope, no staples, and a street address that accepts overnight deliveries.

Corrections, What To Do When Numbers Change

If a merger, audit adjustment, or classification fix changes your data year numbers, file a corrected report and mark the box. If your corrected totals cross the 25 million threshold, e‑file is mandatory, and a paper submission would not count as filed. Keep the IRS e‑file acknowledgment with your records, and if you do not see it within ten days, contact the service team listed in the instructions.

Penalties. Failure to report carried a penalty that started at 10,000 plus an amount based on days late or the fee amount. Verify the exact figure and any inflation adjustments for your specific fee year against 26 CFR Part 57, the separate Instructions for Form 8963, and the controlling IRS Notice before relying on it, because these values do not appear on the form face and have shifted across years. If you are writing a reasonable cause statement, explain facts clearly, attach support, and show how you fixed controls.

Public Disclosure And Documentation Discipline

Plan for daylight. Original and corrected Forms 8963 are open for public inspection or available upon request under section 9010(g)(4). If you work in a controlled group, align everyone on document standards. Use consistent naming for schedules, save source reports with dates, and log the reconciliation choices you made for assumption vs indemnity reinsurance. This is the kind of file you do not want to rebuild from memory later.

A Simple Workpaper Template That Works

• Cover sheet, entity or designated entity name, EIN, contact, fee year, data year, filing method.
• Source index, SHCE parts used, MLR sections used, other state filings, with links or file paths.
• Net premiums written rollforward, show each adjustment line and reference back to source.
• Controlled group Schedule A grid, member identifiers, NAIC codes, and net premiums.
• Signoff checklist, reviewer notes, questions resolved, and e‑file acknowledgment.

The 2020 Finale, Amounts And The Repeal

Two facts close the book. First, the applicable amount for the 2020 fee year was 15,522,820,037. Second, Congress repealed the annual fee for calendar years beginning after December 31, 2020, so there is no fee for 2021 and later. Note that the fee was also temporarily suspended for 2017 and 2019, which is different from this permanent repeal, because during suspension years the §9010 statute and the Form 8963 obligation still existed. If you ever need to explain why the 2020 cycle felt heavier, remember that HHS updated the premium growth measure used in the calculation beginning in 2020, which helped drive the increase from the 2018 base.

For stakeholder updates or a one‑page explainer, keep this sentence handy, 2020 was the last fee year, based on 2019 premium data, and the program ended by statute for 2021 forward.

The Life Cycle In One Glance

Step	Typical timing	What to check
File Form 8963	April 15, fee year	E‑file rule, data year link, controlled group status.
Preliminary notice	By June 15	Compare to your workpapers, prep corrections if needed.
Corrected report window	By July 15	Mark corrected, include support, keep acknowledgment.
Final fee due	September 30	Confirm amount aligns to applicable share.

Controlled Groups, Designated Entities, And Schedule A

You reported as one covered entity if members were treated as a single employer under sections 52 and 414. The designated entity filed, received all IRS correspondence, and paid the fee. Members had to furnish data to the designated entity, and group filings depended on accurate member totals. If you are cleaning up history, verify the membership snapshot as of December 31 of the data year, gather written consents, and remove intra‑group duplication before you finalize Schedule A.

Schedule A, A Short Checklist

• List every member with legal name, EIN, NAIC company and group codes.
• Enter each member’s net premiums written for the data year.
• Attach a reconciliation note if SHCE or MLR sources were incomplete and you used equivalent forms.
• Validate your e‑file formatting, especially the nine‑digit EIN and drop‑down selections for exempt entities.

Pro move, create a one‑page summary of each member’s sources and contacts. When reviewers change, that page prevents slowdowns and re‑work.

E‑File, Paper, And The 2020 Fax Exception

If your data‑year net premiums written exceeded 25 million, you had to e‑file. The rule applies to corrected reports too, and once any Form 8963 for that fee year is filed electronically, all others for that year must be electronic as well. Treat a non‑electronic submission as not filed in that situation.

For the 2020 fee year, the IRS allowed e‑file with Form 8453‑R and a limited fax option. If you still see a reference to fax in an internal wiki, label it historical and point to the archived instructions. For paper filings under the threshold, the 2020 address was Ogden, Utah, with clear rules on flat envelopes and no staples.

Addressing And Signature Standards

• Street address that accepts overnight deliveries, no P.O. boxes.
• For e‑file, use Form 8453‑R to sign.
• For paper, hand‑sign Part I, date it, and include title and phone.
• For foreign addresses, use uppercase country names and follow the input order in the instructions.

Common Mistakes We Still See In Historical Files

We keep seeing the same patterns in old §9010 files when teams reopen them five or six years after the original filing. The form is historical, but the IRS questions, M&A diligence requests, and state regulator follow-ups are not.

FAQ, Straight To The Point

Does Form 8963 still apply after 2020?

No. Congress repealed the annual health insurance providers fee for calendar years beginning after December 31, 2020, so there are no new filings for 2021 and later. Use Form 8963 only for historical corrections and audit support tied to fee years through 2020.

What was the 2020 industry‑wide fee amount?

The 2020 applicable amount was 15,522,820,037. The IRS allocated that total based on each filer’s share of the national net premiums written pool for 2019.

What counted as net premiums written for this form?

Premiums written, including assumption reinsurance, minus reinsurance ceded, ceding commissions, and MLR rebates. Do not include indemnity reinsurance or reduce for indemnity reinsurance ceded.

When did I have to e‑file?

If your report showed more than 25 million in net premiums written, e‑file was required, and any additional or corrected filings for that fee year also had to be e‑filed. Paper would not be considered filed in that case.

Where did paper forms go in 2020, and did the IRS accept fax?

Paper went to the IRS Ogden address listed in the 2020 instructions, and for that year only the IRS allowed faxing Form 8963 with Form 8453‑R. Treat both details as historical references now.

Could the IRS publish what I filed?

Yes. Section 9010(g)(4) allows public inspection of Form 8963 data, including corrected reports. Plan your documentation knowing that your numbers may be visible.

How did the timeline work in a typical year?

File by April 15, preliminary notice by June 15, corrections typically due by July 15, final fee due September 30. Use those dates to reconstruct and explain your historical file.

Practical Checklist You Can Use Today

Use this when you pick up an old file or receive an IRS letter about the 2020 fee year.

• Confirm fee year and data year, then state plainly that the fee does not apply after 2020.
• Identify controlled group membership as of December 31 of the data year, and name the designated entity.
• Rebuild net premiums written using the instruction definitions and tie to SHCE or MLR.
• Reconcile assumption vs indemnity reinsurance, then document any judgment calls.
• Validate whether e‑file was required, and if so, locate the IRS acknowledgment.
• If correcting, mark “Corrected report” and follow the electronic rules if the threshold applies.

Sample Reconciliation Note, One Paragraph

“Net premiums written reflect SHCE Part 2, line 1.1 columns 1‑10 plus 12 for 2019, reduced for MLR rebates per CCIIO filing, plus stand‑alone dental and vision as specified. We included assumption reinsurance written and reduced for assumption reinsurance ceded. We excluded indemnity reinsurance and did not reduce for indemnity reinsurance ceded. See schedules A‑1 through A‑3 and tie‑outs.”

Reusable Checklists

These checklists are copy-paste ready for an SOP page or a workpaper index. Drop them into your historical §9010 review file and check items off as the engagement moves.

Keep 8963 Season From Stalling

Form 8963 work in 2025 is not a filing cycle, it is a cleanup and defense cycle. The §9010 fee was repealed for calendar years after 2020 under FCAA 2020 §502, but health insurers still field IRS correspondence, M&A diligence requests, and state regulator follow-ups tied to fee years 2014, 2015, 2016, 2018, and 2020. The industry-wide applicable amount for fee year 2020 alone was 15,522,820,037 (per the 2020 Instructions for Form 8963), and reconciling that math five years later usually means reopening SHCE Part 2 workpapers, MLR rebate detail, and reinsurance schedules nobody has touched since the original submission.

The pain shows up in three places. Workpapers that never explained how net premiums written were drawn. Controlled group rosters frozen at year-end without the consent evidence the Schedule A claims relied on. Schedule A entries where the data year and fee year were quietly confused. When the IRS or a buyer asks for documentation under §9010(g)(4), the file has to read clean to outside reviewers, because the data is statutorily public, not IRC §6103-protected return information.

• Pull the Schedule A roster and confirm every entity listed independently met the §9010 covered-entity definition at end of day December 31 of the data year. Group members who were not covered entities should not appear there.
• Rebuild net premiums written from SHCE Part 2 line 1.1 columns 1-10 plus 12, then walk through assumption reinsurance additions, indemnity reinsurance exclusions, ceding commissions, and MLR rebates as separate tie-out lines.
• Verify the 50% exclusion claim for any 501(c)(3), (4), (26), or (29) premiums. Only half (not all) of those net premiums comes out of the fee base, per IRC §9010 and 26 CFR Part 57.
• Confirm whether the original report crossed the 25 million net premiums written threshold that required electronic filing, and locate the IRS acknowledgment for that fee year.
• For controlled groups, retrieve the designated entity selection memo and member consents, with box 2a (consolidated IRC §1504 return) or box 2b (other designated entity) checked correctly.

That is the cleanup discipline our team brings to every historical §9010 review. If you are sitting on a 2020 file an IRS examiner just asked about, or a buyer's diligence team flagged §9010 exposure during a health insurer acquisition, our U.S. tax services team can rebuild the workpapers, defend the reported numbers, and document every judgment call before the next request lands.

FAQs

Does Form 8963 still apply after 2020?

No. Congress repealed the annual health insurance providers fee for calendar years beginning after December 31, 2020, so there are no new filings for 2021 and later. Use Form 8963 only for historical corrections and audit support tied to fee years through 2020.

What was the 2020 industry‑wide fee amount?

The 2020 applicable amount was 15,522,820,037. The IRS allocated that total based on each filer’s share of the national net premiums written pool for 2019.

What counted as net premiums written for this form?

Premiums written, including assumption reinsurance, minus reinsurance ceded, ceding commissions, and MLR rebates. Do not include indemnity reinsurance or reduce for indemnity reinsurance ceded.

When did I have to e‑file?

If your report showed more than 25 million in net premiums written, e‑file was required, and any additional or corrected filings for that fee year also had to be e‑filed. Paper would not be considered filed in that case.

Where did paper forms go in 2020, and did the IRS accept fax?

Paper went to the IRS Ogden address listed in the 2020 instructions, and for that year only the IRS allowed faxing Form 8963 with Form 8453‑R. Treat both details as historical references now.

Could the IRS publish what I filed?

Yes. Section 9010(g)(4) allows public inspection of Form 8963 data, including corrected reports. Plan your documentation knowing that your numbers may be visible.

How did the timeline work in a typical year?

File by April 15, preliminary notice by June 15, corrections typically due by July 15, final fee due September 30. Use those dates to reconstruct and explain your historical file.