6 pages. "[The] Council urges the Service to provide a transition period allowing good faith compliance for the first two years the [Patient-Centered Outcomes Research Trust Fund Fee (PCORI)] is in effect.... [The Council requests] that issuers and employers be permitted to determine the number of covered lives using a 'dependency' coefficient in lieu of having to count the actual number of covered lives enrolled in a given plan.... Since employers are required by federal law to offer COBRA coverage, it would seem inappropriate to impose a PCORI Fee on employers with respect to such coverage.... [T]he Council requests that the Service issue guidance confirming that the PCORI Fee will not be imposed with respect to retiree health coverage to help ensure that employers remain willing and able to provide this coverage ... [A]dditional clarification would be helpful to confirm our reading of the Proposed Regulations that similar self-funded Expatriate Plans are also excepted for purposes of the PCORI Fee.... [The Council requests] that the Service issue guidance permitting TPAs to fulfill payment and reporting obligations with respect to the PCORI Fee on behalf of sponsors of self-insured plans."