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•    The 2026 rate is $3.84 per covered life, due July 31, 2026 for plan years ending in 2025.

•    Fully insured plans: the carrier files and pays. Self-funded and level-funded plans: you do.

•    Sponsor an HRA, ICHRA, or QSEHRA next to a fully insured plan and you likely still owe the fee.

•    Count covered lives with one of three IRS methods: actual count, snapshot, or Form 5500.

•    Miss the deadline and you face 5% per month up to 25%, plus interest.

PCORI fees are an annual fee under the Affordable Care Act. They fund the Patient-Centered Outcomes Research Institute, a nonprofit that runs comparative effectiveness research. You pay per covered life and report on IRS Form 720.

For 2026, the rate's $3.84 per covered life for plan years ending between October 1, 2025 and September 30, 2026. The PCORI due date is July 31, 2026.

It all comes down to one question: is your plan self-funded or fully insured? Plenty of employers see fully insured coverage and assume they're done. They're often not. Sponsor an HRA alongside that plan and you may still owe PCORI fees. So nail down your plan structure before you file anything. For the full steps, see our PCORI fee guide.

With a fully insured plan, you buy coverage from a carrier and pay premiums. The carrier carries the claims risk, so it handles PCORI for that medical plan, the math, the filing, the payment. You don't touch Form 720 for it.

With a self-funded plan, you pay claims from company funds and own the risk. You're the plan sponsor even when a TPA runs day-to-day. That means you count covered lives, file Form 720, and pay the fee.

A level-funded plan feels like insurance, but for PCORI it counts as self-funded, and the employer usually files and pays.

fully insured employers aren't off the hook. Sponsor any HRA, ICHRA, or QSEHRA beside your insured plan, and you likely owe PCORI fees as the plan sponsor.

Handing it to a TPA won't move the obligation either. The IRS still looks to the plan sponsor.

HRAs trip up the most people, so here's how each setup shakes out:

•    Fully insured plan + HRA: the insurer covers the medical plan, but you pay a separate fee for the HRA. Count enrolled employees only, no dependents ($3.84 × participants).

•    Self-funded plan + integrated HRA: same sponsor, same plan year? Count covered lives once. No separate HRA fee.

•    ICHRA and QSEHRA: always self-insured. You owe the fee even when the underlying individual coverage is fully insured. Employees only.

•    GCHRA: subject to the fee unless excepted. Dental-only and vision-only HRAs get a pass.

HRA PCORI fees get messy fast, so double-check your plan year dates.

•    Multiple self-funded plans, one employer: treat them as a single plan and count each person once.

•    Short plan years: each one needs its own calculation, and there's no prorated fee. You owe the full amount.

•    MEWAs and VEBAs: the named plan sponsor is on the hook. No sponsor named? Each employer owes its share.

•    Retiree-only plans: subject to the fee if they're self-insured.

•    Excepted benefits (no fee): dental-only and vision-only HRAs, most excepted FSAs, and accident or disability coverage.

PCORI Fee = Average Covered Lives × Applicable Rate

For example, a plan with 120 covered lives would owe $460.80 (120 × $3.84).

1. Actual Count Method
Average the total covered lives counted each day of the plan year. Most accurate but requires detailed records.

2. Snapshot Method
Count covered lives on selected dates each quarter and average them. IRS factors can simplify dependent counts.

3. Form 5500 Method
Use participant counts from Form 5500 if IRS eligibility requirements are met.

Choose the method that best fits your records, use it consistently, and confirm counts with your TPA.

Try our PCORI fee Calculator which calculates your PCORI Fee within seconds.

The fee's due July 31 of the year after your plan year ends. Form 720 is technically a quarterly return, but PCORI gets reported and paid just once, on the second-quarter filing. If July 31 falls on a weekend or holiday, you get until the next business day.

You can mail Form 720 with a payment or file online through an authorized platform. E-filing through QuickFile720 is faster, trims errors, and gives you instant IRS acknowledgment.

Blow the deadline and the IRS failure-to-file penalty runs 5% of unpaid tax per month, up to 25%, plus interest from the due date. The plan sponsor files and pays directly, since a TPA can't do it for you. Made an error? Fix it with Form 720-X, and you can appeal a penalty if you had reasonable cause.

Q1. Does the PCORI fee apply even if our plan year is shorter than 12 months?

Yes. The PCORI fee applies to short plan years just like any other plan year. The fee equals the average number of lives covered during that short plan year multiplied by the applicable dollar amount for the year it ends in. There is no prorated rate; the full per-life amount applies.

Q2. Do COBRA participants, retirees, and dependents count toward covered lives?

Yes. All individuals covered during the plan year must be counted: employees, dependents, retirees, former employees, and anyone on COBRA continuation coverage. Each person counts as a separate covered life. 

Q3. Which types of plans are exempt from the PCORI fee?

Plans that provide only excepted benefits, such as dental-only or vision-only coverage, are not subject to the fee. Most health FSAs also fall under this exemption. Plans limited to employee assistance programs, disease management programs, or wellness programs are exempt as long as they do not provide significant medical care benefits. Certain federal programs such as Medicare, Medicaid, and CHIP are also exempt.

Q4. What form is used to report and pay the PCORI fee, and when is it due?

Plan sponsors of applicable self-insured health plans file Form 720, Quarterly Federal Excise Tax Return, once a year to report and pay the PCORI fee. The return is due July 31 of the calendar year following the last day of the plan year. If you have no other liabilities to report on Form 720, you only need to file it once; you are not required to file for the other quarters.

Q5. Does using a TPA shift the PCORI filing obligation away from the employer?

No. The IRS holds the plan sponsor, the employer, responsible for reporting and paying the PCORI fee. Outsourcing plan administration to a TPA does not transfer that obligation. Even if your TPA handles the day-to-day plan management, the employer must file Form 720 and make the payment directly.

Where to Start: Know Your Obligation Before July 31

The self-funded versus fully insured line looks clean until HRAs, ICHRAs, QSEHRAs, or level-funded plans show up. Before July 31, 2026, confirm whether your plan is fully insured, self-funded, or level-funded, whether you sponsor an HRA, which counting method applies, and whether the filing falls on you.

Penalties sting, but the real danger is learning years later that a return never got filed. Run the check now, while there's still time to fix it.

File Your PCORI Fee Online in Minutes. QuickFile720's IRS-authorized e-filing platform helps employers submit Form 720 quickly and accurately.