The 2026 PCORI fee is $3.84 per covered life for plan years ending on or after October 1, 2025 — which includes every 2025 calendar-year plan — and it must be reported and paid to the IRS by July 31, 2026, on the second-quarter Form 720. Plan years that ended between January and September 2025 pay last year’s rate of $3.47.
Fully insured groups can ignore all of this — the carrier pays. The clients who get burned are the level-funded and self-funded groups, and if you’ve been moving small groups into level-funded plans over the past few years, that’s a growing slice of your book. Most of them have never filed a federal excise tax return in their lives, and their TPA is legally barred from filing it for them.
The 2026 PCORI Fee Numbers
The IRS set the new rate in Notice 2025-61. The fee due this July applies to plan years that ended anytime in calendar year 2025, and the rate depends on when the plan year ended:
- Plan years ending January–September 2025: $3.47 per covered life
- Plan years ending October–December 2025: $3.84 per covered life (this is the rate for calendar-year plans)
Quick answer: A 2025 calendar-year self-funded or level-funded plan owes $3.84 per average covered life, filed on the Q2 2026 Form 720, due July 31, 2026.
The fee dates back to the ACA, funds the Patient-Centered Outcomes Research Institute, and is scheduled to run through plan years ending before October 1, 2029 — so this is an annual conversation, not a one-time cleanup.
Which Clients in Your Book Have Exposure
The fastest way to work this deadline is to segment your groups by funding type. Here’s the whole map:
| Client type | Who files and pays | What’s counted |
|---|---|---|
| Fully insured medical | The carrier — no client action | N/A (built into premium) |
| Level-funded medical | The employer | Average covered lives, including dependents |
| Self-funded medical | The employer | Average covered lives, including dependents |
| Fully insured medical + HRA | Carrier pays for the medical plan; the employer files for the HRA | One life per enrolled employee — HRA dependents don’t count |
| Self-funded medical + HRA (same plan year) | The employer, but only once | Covered lives on the medical plan; the HRA isn’t double-counted |
Dental and vision plans that qualify as excepted benefits — which is nearly all of them — are exempt. So are health FSAs and HSAs. If you want the full applicability grid, the IRS publishes a chart covering every common arrangement.
Quoting level-funded groups? We’ll get you non-BUCA carrier options.
The Level-Funded Trap
Here’s the miss that happens every July. A level-funded group pays a fixed monthly amount to a carrier, gets ID cards from that carrier, and reasonably assumes they’re fully insured. They’re not. Level-funded plans are self-insured plans under the tax code, which puts the PCORI filing obligation squarely on the employer.
Three things make this worse. First, the carrier won’t invoice the client for it — many level-funded carriers post a covered-lives report to their portal in June and consider their job done. Second, the TPA is prohibited from remitting the fee on the employer’s behalf; the plan sponsor has to sign and file its own Form 720. Third, a group that moved from fully insured to level-funded mid-book has literally never seen this form before, so nothing in their annual routine flags it.
The conversation worth having: every level-funded client that renewed with you gets a short email in June. It should say who owes the fee, the per-life rate, where to pull their covered-lives count, and the July 31 date. That email costs you ten minutes and saves the client a late-payment penalty plus interest — and it’s the kind of touch that gets remembered at renewal.
[E-E-A-T spot — your specifics go here]: If BrokersBloc sends brokers a PCORI reminder kit, a covered-lives report walkthrough for specific level-funded carriers, or has a story about a group that missed a filing and what fixing it took, this is the place. Delete this callout if you’d rather skip it.
How the Fee Is Calculated
The fee is the applicable rate times the average number of covered lives for the plan year. The IRS allows three counting methods, summarized in its PCORI fee FAQs:
- Actual count method — average the covered lives on every day of the plan year
- Snapshot method — count lives on one or more consistent dates per quarter and average them
- Form 5500 method — use participant counts already reported on the plan’s Form 5500
A worked example: a level-funded group with a 2025 calendar plan year averages 42 covered lives (employees plus dependents). The fee is 42 × $3.84 = $161.28. Small dollars — which is exactly why clients don’t take it seriously until the IRS notice shows up.
One wrinkle for HRAs: the employer counts only one life per participating employee, not dependents. And if the client runs a self-funded medical plan and an HRA on the same plan year, the fee applies once, to the medical plan’s covered lives — no double payment.
Filing Mechanics in 90 Seconds
The PCORI fee always goes on the second-quarter Form 720, regardless of the client’s plan year. Quarter ending June, filing year 2026. Self-insured plan sponsors report in Part II, line 133 — line (c) for plan years that ended before October 1, 2025, line (d) for plan years ending on or after that date. Enter the average covered lives, multiply by the rate, carry the total through to the balance due. Payment goes by check with the 720-V voucher or electronically through EFTPS (applied to Q2). Paper filings need a wet signature; e-filing through an IRS-approved provider allows an electronic one. The details live in the Form 720 instructions.
One coordination note: Form 720 covers all federal excise taxes. If your client’s accountant already files a 720 for other reasons, the PCORI line goes on that same Q2 return — loop the tax preparer in rather than filing a duplicate.
PCORI Fee FAQ
Does the PCORI fee apply to dental and vision plans?
No, as long as they qualify as excepted benefits, which nearly all standalone dental and vision plans do. The fee applies to major medical plans and HRAs.
Do level-funded plans have to pay the PCORI fee?
Yes. Level-funded plans are self-insured plans for PCORI purposes, so the employer must file Form 720 and pay $3.84 per covered life for a 2025 calendar plan year by July 31, 2026.
Can the TPA or broker file the PCORI fee for the client?
No. The plan sponsor must file and pay the fee itself. A TPA or vendor can help calculate the covered-lives count, but the employer signs and submits the Form 720.
What if a client missed a PCORI filing in a prior year?
They should file as soon as possible using the rate that applied to that plan year, on that year’s version of Form 720. Late filings can trigger penalties and interest, though the IRS may waive penalties for reasonable cause.
Do FSAs and HSAs owe the PCORI fee?
No. Health FSAs must be excepted benefits under the ACA, and HSAs are not group health plans, so neither is subject to the fee.
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