PCORI Fee Due July 31, 2026
PCORI Fee Due July 31, 2026
5/12/2026
While the IRS has revised Form 720 as of March 2026, there will be another revision before the reporting deadline of PCORI Fees to include the most current amounts needed to report PCORI Fees. This form is used to report and pay the fees that are due by July 31 of every year.
Employers who sponsored self-funded/level funded medical plans that ended sometime during 2025 are required to report and pay the ACA Patient-Centered Outcomes Research Institute (PCORI) fee no later than July 31, 2026. Form 720 should be filed for the 2nd quarter ending June 30th, 2026.
Background
General summary information for PCORI fees can be found on the IRS website.
Health insurance carriers pay the fee on behalf of fully insured plans, but employers are responsible for reporting and paying the fee for any self-funded/level funded group health plans, including Health Reimbursements Arrangements (HRAs). The PCORI fee applies to most group health plans, including retiree-only plans, but not to excepted benefits. The IRS published a chart that describes the different types of plans subject to the fee.
The fee is paid for self-funded/level funded group health plans using quarterly excise tax Form 720, Line 133(c) and (d), and must be paid by July 31st of the year following the last day of the plan year. The PCORI fee should be reported in the 2nd quarter of the calendar year following the end of the plan year, rather than filing sooner, to avoid any confusion for the IRS over which plan year the reporting applies to. If any corrections need to be made for prior years, use Form 720X.
Fee Amount
Payment amounts due in 2026 will differ based on the employer’s plan year. The fees due in July 2026 are as follows:
- $3.47 per covered life for plan years ending in January – September 2025 - to be filed July 31, 2026.
- $3.84 per covered life for plan years ending in October – December 2025 - to be filed July 31, 2026.
- $3.84 per covered life for plan years ending in January - September 2026 - to be filed July 31, 2027.
Calculating the Average Covered Lives
Self-funded plans may use one of three methods to determine the average covered lives used for reporting and paying the PCORI fee:
- the actual count method;
- the snapshot method; or
- the Form 5500 method. It is okay to switch between counting methods from one year to the next to use whichever method results in the lowest number of covered lives.
There are special rules that apply for employers offering multiple self-funded/level funded plans and for employers paying the fee for a stand-alone HRA or for an HRA integrated with a fully insured plan. These special counting rules are outlined below.
Multiple Self-Funded/Level Funded Plans – If one plan sponsor maintains more than one self-funded/level funded health plan with the same plan years, the arrangements can be treated as a single plan for purposes of the fee, in which case each unique participant (employee and dependents) is counted for purposes of calculating the fee.
HRAs – For an employer paying the PCORI fee solely for an HRAs, the employer is required to pay the fee only with respect to participating employees (not required to include dependents or beneficiaries). If an employer is offering an HRA to cover out-of-pocket expenses of a fully insured group health plan, the employer is required to pay the fee again only with respect to participating employees (not dependents or beneficiaries).
Penalties - The PCORI rules do not contain a specific penalty for failure to report or pay the PCORI fee, but since this fee is considered an excise tax, any related penalty for failure to file a return or pay a tax would seem to apply. Code §6651 includes the penalties for failure to file a return or pay taxes.
Resources
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