PCORI Fee Due July 31, 2026

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. 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.

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.

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).