Upcoming PCORI filing deadline: Due July 31, 2026

May 2026 

Stephanie Hall, Associate Director Benefits Compliance 

The upcoming deadline for health insurance issuers and plan sponsors of self-insured health plans to report and pay their PCORI fee is July 31, 2026.

The Affordable Care Act (“ACA”) imposes a fee on specific health insurance issuers and plan sponsors of applicable self-insured health plans (regardless of size) to help fund the Patient-Centered Outcomes Research Trust Fund, which is the funding source for the Patient-Centered Outcomes Research Institute (“PCORI”). While the PCORI fee generally applies to self-insured group health plans, the regulations contain some exceptions to this rule. For example, the fee does not apply if substantially all of the coverage under a plan is for excepted benefits (as defined under the Health Insurance Portability and Accountability Act), such as stand-alone dental and vision plans and accident-only coverage. Further, plans that are limited to employee assistance programs, disease management programs, or wellness programs are not subject to the PCORI fee if these programs do not provide significant benefits in the nature of medical care or treatment.

There are special rules for health flexible spending accounts (“FSAs”) and health reimbursement arrangements (“HRAs”). Basically, the regulations allow the plan sponsor to assume one covered life for each employee with an HRA or health FSA that is not an excepted benefit. In addition, a plan sponsor may treat multiple self-insured plans with the same plan year as a single plan for reporting and payment purposes. For example, a plan sponsor with a self-insured plan providing major medical benefits and a separate self-insured plan with the same plan year that provides prescription drug coverage may be considered as a single plan so that the same covered life under each plan is counted only once.

The insurance company is responsible for filing and paying the fee where the health plan is fully insured with no integrated HRA. If the health plan is insured but has an integrated HRA, the employer (as the plan sponsor) is required to file only with respect to the HRA, and the insurer will file on the health plan separately.

The PCORI fee is reported and paid annually using IRS Form 720 (Quarterly Federal Excise Tax Return). The fee is due each year by July 31 of the year following the last day of the plan year. If the due date falls on a Saturday, Sunday, or legal holiday, the form may be filed on the next business day. The PCORI fee may not be paid from plan assets and must be paid separately by the plan sponsor.

The PCORI fee is calculated based on the average number of lives covered under the policy or plan. This generally includes employees and their enrolled spouses and dependents unless the plan is an HRA or FSA as discussed above. Individuals receiving continuation coverage (such as COBRA coverage) must also be included in the calculation. The number of covered lives is multiplied by the applicable rate for the specific plan year. The following amounts apply to the upcoming filing for plans that ended in 2025:

• Plan year ended between January 1, 2025 – September 30, 2025: $3.47/covered life

• Plan year ended between October 1, 2025 – December 31, 2025: $3.84/covered life

The final regulations provide the following methods for a plan sponsor to use to determine the average number of covered lives for each plan year:

• Actual count method: Covered lives are determined on each day of the plan year, and the result is averaged over the total number of days in the plan year.

• Snapshot method: The number of covered lives is determined on the same day (plus or minus three days) of each quarter (or month, if desired) and averaged. As a possible shortcut, rather than counting dependents, the number of employees who have dependent coverage may be multiplied by 2.35 and added to the number with employee-only coverage to determine total covered lives.

• Form 5500 method: For health plans that are required to file IRS Form 5500 (those with 100 or more participants as of the first day of the plan year), alternative methods of counting are available depending on whether dependent coverage is offered. Form 5500 must be filed by July 31 to use this option.

Many employers only file Form 720 once each year for the sole purpose of reporting PCORI information. This means that they file the form only for the second quarter of the year (which would reflect “June 30” in the quarter ending section of the form, regardless of the plan year ending date). Employers that are required to file Form 720 each quarter because of other excise tax liabilities will need to remember to complete the PCORI section of the form (in Part II) only for the second quarter filing (again, regardless of the plan year ending date).

The form may be paper filed via the U.S. Postal Service or a designated private delivery service or it may be filed electronically through any electronic return originator, transmitter, and/or intermediate service provider participating in the IRS e-file program for excise taxes. While not required, the IRS recommends paying the fee electronically. If paid through the Electronic Federal Tax Payment System, the plan sponsor should make sure to note that the payment applies to the second quarter.

Employer action items

• Determine whether the employer’s offered plans are covered under the ACA’s PCORI rules, and if so, determine whether the employer is responsible for filing Form 720 and paying the fee.

• Select an allowable method to be used to determine the number of covered lives and calculate the total fee amount using the applicable rate for the plan ending date.

• Watch for the release of the updated Form 720 (which is usually toward the end of May or the beginning of June) so that the form can be filed and the fee paid prior to the July 31 deadline (employers are cautioned to wait until the form is updated before filing).

Additional information and resources

• IRS General PCORI Information
• IRS PCORI Q&A
• IRS information on which policies and plans are subject to the PCORI rules
• IRS Excise Tax e-File