$3.84 PCORI Fee Due July 31
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$3.84 PCORI Fee Due July 31
By Brian Gilmore | Published May 13, 2026
Executive Summary
IRS Notice 2025-61 adjusts the Patient-Centered Outcomes Research Institute (PCORI) fee to $3.84 per covered individual for health plan years ending on or after October 1, 2025 and before October 1, 2026, including 2025 calendar plan years. This represents a 37-cent increase from last year’s $3.47 PCORI fee.
- Action Item: The annual PCORI fee must be reported and paid to the IRS by July 31, 2026, via the second quarter Form 720 (Rev. June 2026).
Which Entity is Responsible for Paying the PCORI Fee?
The PCORI fee is imposed on health insurance issuers and self-insured health plan sponsors (employers).
Fully Insured Medical Plans: Health Insurers are responsible for paying the fee on fully insured health policies. This fee is built into the insurance premium, so there is no action required by employers.
Self-Insured Medical Plans: The employer is responsible for paying the PCORI fee for self-insured health plans. Self-insured plans include level funded plans.
To Which Plans Does the PCORI Fee Apply?
The PCORI fee generally applies only to major medical plans and health reimbursement arrangements (HRAs).
The PCORI fee does not apply to dental and vision coverage that is an excepted benefit, whether through a stand alone insurance policy or meeting the “not integral” test for self-insured coverage. Virtually all dental and vision plans are excepted benefits. The PCORI fee also does not apply to health FSAs (which must be an excepted benefit to comply with the ACA) or HSAs, which are not group health plans.
For a quick reference guide, the IRS has published a table which summarizes the applicability of the fee to common types of health and welfare benefits.
- Action Item: The employer must file the Form 720 and pay the fee for a self-insured or level funded medical plan or HRA.
How Does the PCORI Fee Apply to HRAs?
Health reimbursement arrangements (HRAs) are subject to the PCORI fee because they are self-insured health plans. This includes HRAs designed to cover cost-sharing under the major medical plan, SIHRAs, ICHRAs, QSEHRAs, and specialty HRAs such as those designed to cover infertility, medical travel assistance, gender affirmation, mental health, GLP-1s, and other specific medical expenses.
Fully Insured Medical Plan with an HRA: The insurance carrier is responsible for paying the PCORI fee for the insured medical plan. The employer is responsible for paying the PCORI fee based on the number of employees enrolled in the HRA.
Self-Insured Medical Plan with an HRA: As long as the self-insured medical plan and HRA have the same plan year, the employer is responsible for paying the PCORI fee only for the self-insured medical plan (not the HRA). This nonduplication rule applies for employees who are enrolled in the employer’s self-insured medical plan and also enrolled in an HRA.
The HRA PCORI fee amount is determined by a special rule that counts only one life per employee participating in the HRA. Unlike major medical plans, dependents covered by an HRA are not subject to the fee.
- Action Item: The PCORI fee is required for an HRA unless the employee is also enrolled in the employer’s self insured major medical plan that has the same plan year as the HRA.
How is the PCORI Fee Calculated?
Plan Sponsors can use one of three alternative methods which are summarized by the IRS in its PCORI fee homepage and PCORI fee FAQs to determine the average number of covered lives:
- Actual count method
- Snapshot method
- Form 5500 method
Determining the Applicable PCORI Fee Amount Due July 31, 2026
The PCORI fee is due with the IRS Form 720 by July 31 of the calendar year following the end of the plan year. The PCORI fee due this July therefore applies to plan years that ended in 2025:
- Plan Years Ending January 2025 – September 2025: $3.47 per covered life.
- Plan Years Ending October 2025 – December 2025: $3.84 per covered life.
The applicable rate for a 2025 calendar plan year is $3.84 per covered life. The plan year is the ERISA plan year, as reflected in the wrap plan document/SPD and Form 5500 (if applicable). The PCORI fee also applies to short plan years.
Examples:
- Employer with a calendar plan year first changed to a self-insured medical plan (including level funded) effective January 1, 2025. Employer must file the first Form 720 to pay the PCORI fee in July of 2026 based on the $3.84 PCORI rate.
- Employer with a calendar plan year first changed to a self-insured medical plan (including level funded) effective January 1, 2026. Employer must file the first Form 720 to pay the PCORI fee in July of 2027.
- Employer with a July 1 – June 30 plan year first offered a self-insured medical plan (including level funded) effective July 1, 2025. Employer must file the first Form 720 to pay the PCORI fee of $3.84 per covered life in July of 2027.
- Employer with a self-insured medical plan (including level funded) had a short plan year from July 1, 2025 through December 31, 2025 to transition to a calendar plan year as of 2026. Employer must file the Form 720 in July 2026 to pay the PCORI fee for both the full plan year ending June 30, 2025 ($3.47 per covered life) and the short plan year ending December 31, 2025 ($3.84 per covered life).
How to File the PCORI Fee Payment
The PCORI fee is always filed on the second quarter IRS Form 720, regardless of the employer’s plan year. The second quarter Form 720 is due by July 31. Form 720 is used to pay the multiple forms of quarterly federal excise taxes. Employers should coordinate with their accounting team and tax preparers if they file other excise taxes on the Form 720.
Instructions for Completing the PCORI-Related Portions of IRS Form 720
Page 1:
- The employer must enter the name, address, and employer identification number at the top of the form.
- “Quarter ending” is June, and the year in which they are filing (2026).
- “Final return” should be checked if the employer no longer maintains a self-insured medical plan or HRA.
- “Address change” should be checked if the employer has changed their address since the last filing.
Page 2:
- Skip to Part II, (if no other taxes are being paid on this form) line 133 – “Applicable self-insured health plans”. Line (c) is for plan years ending before October 1, 2025 (non-calendar year plans) and line (d) is for plan years ending on or after October 1, 2025 (generally calendar year plans). Note that Lines (a) and (b) are for insurance carriers only. Employers do not complete these lines.
- The average number of covered lives should be entered using one of the methods outlined above. An employer may enter the number of lives on both lines if they are filing for a full 12-month plan year and a short plan year.
- The number of lives in lines (c) or (d) is multiplied by the rate in column b and the result is entered in column (c) “Fee”.
- The total of lines (c) and (d) in the Fee column is brought over to the “Tax” column.
- The same total in the “Tax” column is brought down to line 2 “Total” at the bottom of the page.
Page 3:
- Line 3: The same “Total” from Line 2 is brought forward to this line.
- Line 10: The amount from line 3 is brought down to line 10 in “Balance Due”.
- The form needs to be signed and dated and returned with payment.
Signature
The Form 720 can be signed by any person authorized by the employer to sign these types of returns. A wet signature is required unless the Form 720 is e-filed using one of the approved e-file providers.
Methods of Payment
Employers paying via check must complete the payment voucher 720-V at the end of the form with their EIN, amount paid, business name and address. The tax period is 2nd Quarter. Alternatively, employers can pay the PCORI fee through EFTPS. This payment method is available for both e-filed and paper returns. EFTPS payments should be applied to the second quarter.
Electronic Filing of the Form 720
Employers wishing to e-file the Form 720 must use one of the IRS-approved e-file providers. Forms that are e-filed can have an electronic signature. Employers filing a paper Form 720 must have a wet signature but can still pay electronically through EFTPS.
Consult the IRS Instructions for Form 720 for additional directions on completing the form (see page 9).
Summary
| Employer Health Plan Offering: | PCORI Fee Paid By: | Payment Amount: |
|---|---|---|
| Fully Insured Medical Plan | Insurance Carrier | Paid by Carrier |
| Fully Insured Medical Plan + HRA | Employer (for HRA only) | Average Employees Enrolled in HRA (not including dependents) |
| Self-Insured Medical Plan | Employer | Average Covered Lives (including dependents) |
| Self-Insured Medical Plan + HRA | Employer | Generally, Average Covered Lives for Medical Plan (not HRA) |
Disclaimer: The intent of this analysis is to provide the recipient with general information regarding the status of, and/or potential concerns related to, the recipient’s current employee benefits issues. This analysis does not necessarily fully address the recipient’s specific issue, and it should not be construed as, nor is it intended to provide, legal advice. Furthermore, this message does not establish an attorney-client relationship. Questions regarding specific issues should be addressed to the person(s) who provide legal advice to the recipient regarding employee benefits issues (e.g., the recipient’s general counsel or an attorney hired by the recipient who specializes in employee benefits law).
The Author
Brian Gilmore
Lead Benefits Counsel, VP, Newfront
Brian Gilmore is the Lead Benefits Counsel at Newfront. He assists clients on a wide variety of employee benefits compliance issues. The primary areas of his practice include ERISA, ACA, COBRA, HIPAA, Section 125 Cafeteria Plans, and 401(k) plans. Brian also presents regularly at trade events and in webinars on current hot topics in employee benefits law.