- On July 1, 2026
Under the ACA, all medical plans are responsible for paying the Patient-Centered Outcomes Research Institute (PCORI or PCOR) fees to the IRS, based on the average number of plan participants in the reporting plan year. If the medical plan is insured, the insurance carrier pays the fee on behalf of the policyholder. If the medical plan is self-insured, including an HRA, the employer/plan sponsor must file the Form 720 and pay the fees to the IRS directly.
HRAs (including retiree-only plans) that reimburse medical expenses are subject to PCORI fees even if integrated with an insured group medical plan. However, self-insured plans that are primarily for employees working/residing outside of the U.S. or only reimburse excepted benefits do not pay PCORI fees. Excepted benefits include if reimbursement is only for dental/vision expenses.
If your medical plan year ended January 1–September 30, 2025, the fee is $3.47 per covered life. If your medical plan year ended October 1–December 31, 2025, the fee is $3.84 per covered life.
The total due is calculated by multiplying the applicable fee by the average number of covered lives using an available method. The most common method to count covered lives is the “snapshot method”, which averages the covered lives on a day each quarter of the plan year. For example, for calendar year plans, you could count covered lives on January 1, April 1, July 1, October 1, and divide by 4. You would then multiply that number by $3.84 to calculate the total amount due for a plan year that ended December 31, 2025.
Covered lives includes employees and dependents. However, for an HRA, only count employees. To help you calculate by any available method, you can use
The Form 720 and instructions (starting on page 10 for “Applicable self-insured health plans”) are available on the IRS website. On the form, employers/plan sponsors need to complete:
- Company information including that the “Quarter ending” is “June 2026”
- Part II, IRS No. 133
- Column (a) – on the lines for “Applicable self-insured health plans”, enter the “Avg. number of lives covered” in either row (c) or (d), depending on the plan year ending date
- Column (c) – enter total Fee (lives x either $3.47 or $3.84)
- Tax column – enter the amount of the fee (from Column (c))
- Part II, Line 2 – enter Total Tax (from Tax column on No. 133)
- Part III, Line 3 – enter Total Tax again
- Part III, Line 10 – enter Balance Due, which is the Total Tax
- Signature section
- Pay electronically via EFTPS, or pay by check and complete the payment voucher (last page) with “2nd Quarter” box checked