PCORI Fees: Who Pays, Rates and Form 720 Deadlines
Determine who pays PCORI fees, select the rate by plan-year ending date, count covered lives and prepare Form 720 for the July 31 deadline.
2 min readBy Dustin Neider
Key Takeaways
- The insurer pays for specified fully insured policies; the sponsor pays for applicable self-insured plans.
- Choose the rate by the plan-year ending date, not the filing year.
- Count covered lives under an approved method, including dependents where required.
- Form 720 and payment are due July 31 following the calendar year the plan ends.
The PCORI fee funds comparative health research through the Patient-Centered Outcomes Research Trust Fund. For U.S. group coverage, insurers pay for specified fully insured policies; employers sponsoring applicable self-insured plans generally pay for those plans. Multiply average covered lives by the IRS rate for the year ending date, then file Form 720 and pay by July 31 of the following calendar year.
Who pays, and which arrangements need review?
The IRS PCORI questions and answers distinguish insurance issuers from self-insured plan sponsors. Level-funded arrangements generally require the self-insured sponsor to address the fee; stop-loss insurance does not make the medical plan fully insured. A third-party administrator may help calculate lives, but confirm filing responsibility in writing.
An HRA paired with fully insured medical coverage may create a separate sponsor obligation. Excepted-benefit dental or vision plans and most health FSAs are excluded. Certain employee assistance, disease-management and wellness programs are excluded if they do not provide significant medical benefits. Do not assume every FSA or supplemental arrangement qualifies.
Which rate applies?
The IRS rate table, checked October 21, 2026, lists these rates. Select by plan or policy year ending date, not the filing year. Do not extend a listed rate to later ending dates without checking the IRS.
| Plan year ends | Fee per average covered life |
|---|---|
| October 1, 2024–September 30, 2025 | $3.47 |
| October 1, 2025–September 30, 2026 | $3.84 |
Example: an applicable self-insured calendar-year 2025 plan with 100 average covered lives owes 100 × $3.84 = $384. Form 720 and payment were due July 31, 2026. A plan ending September 30, 2025 instead uses $3.47, even though its filing also falls in 2026.
How do you count lives and file?
Self-insured sponsors may use the actual count, snapshot or Form 5500 method, subject to each method's conditions. Insurers also have member-months and state-form methods. Covered dependents, COBRA participants and retirees generally count, not just employees. Special HRA and FSA rules may apply; document the method rather than using employee headcount.
- Confirm the plan year, funding status and applicable arrangements.
- Reconcile enrollment data and retain the counting calculation.
- Use the current second-quarter Form 720 to report the annual fee and pay by July 31 following the year the plan ends.
- Follow current payment instructions. Form 720-V is a payment voucher where applicable, not an attachment required for every payment method. PCORI deposits are not required.
Coordinate the filing calendar with employer HR compliance support. Software does not reduce the statutory rate or replace the approved counting rules.
General information, not legal, tax, or medical advice; plan documents and current rules control.
For employer plan support, request a group health insurance quote.
Frequently Asked Questions
Who pays for a fully insured group plan?
The issuer generally pays for the specified policy. An employer may still owe a separate fee for an applicable self-insured arrangement, such as certain HRAs.
What is the fee for a calendar-year 2025 self-insured plan?
The rate is $3.84 per average covered life; 100 lives produces a $384 fee. Filing and payment were due July 31, 2026.
Is employee headcount enough?
Employee headcount alone is generally insufficient to calculate PCORI fees. Covered dependents and other participants generally count as covered lives; use an IRS-approved counting method and check any arrangement-specific exceptions.
About the author
Dustin Neider — President of PCI Solutions, insurance broker and ACA specialist with nearly 20 years of experience in health insurance.
