2026 PCORI Fee Deadline for Self-Insured Plans
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Article Summary
The 2026 Patient-Centered Outcomes Research Institute (PCORI) fee is due July 31, 2026, for self-insured health plan sponsors. This guide explains who must file Form 720, how to calculate the $3.84 per covered life fee, which covered lives count, and the rules for HRAs, ICHRAs, QSEHRAs, and level-funded plans.
The Affordable Care Act (ACA) imposes a fee on issuers of specified health insurance policies and plan sponsors of applicable self-insured health plans to help fund the Patient-Centered Outcomes Research Institute (PCORI).
For more information on whether a type of insurance coverage or arrangement is subject to the fee, the IRS has provided this useful chart. Do note that self-insured health plans include health reimbursement arrangements (HRAs) and level-funded arrangements. This fee applies to policy or plan years ending on or after October 1, 2012, and before October 1, 2029.
Prefer a quick overview? Watch our Employer Compliance IN FOCUS video for a concise breakdown of 2026 PCORI Fee Deadline for Self-Insured Plans and what employers need to do before the deadline.
Who Must Pay the 2026 PCORI Fee?
Self-insured plan sponsors can satisfy their compliance obligations by completing and filing Form 720, with its accompanying 720-V payment voucher. Although Form 720 is a quarterly return, for PCORI purposes, it is only filed once per year – for the second quarter – regardless of a plan's fiscal year.
Plan sponsors of self-insured health plans and health insurers must pay fees equal to the applicable fee times the average number of covered lives. Plan sponsors cannot pay these fees via the plan or with plan assets.
2026 PCORI Fees: Rates, Calculations, and Deadline
The applicable fee per covered life is determined by the end of the plan year. Per IRS Notice 2025-61, the updated rates are as follows:
| Plan Years Ending | 10/01/2024 - 9/30/2025 | 10/01/2025 - 12/31/2025 |
|---|---|---|
| Fee Per Covered Life | $3.47 | $3.84 |
| Payment Due Date | July 31, 2026 | July 31, 2026 |
Key deadline: For most calendar-year plans ending December 31, 2025, the applicable rate is $3.84 per covered life, and the filing and payment deadline is July 31, 2026. This is the largest single-year PCORI fee increase to date – up $0.37 from the prior year (IRS Notice 2025-61).
There are three methods for calculating the average number of covered lives, including the Actual Count Method, Snapshot Method, and 5500 Method. The IRS has issued detailed guidance on the multiple methods that can be used to calculate the PCORI fee. As a reminder, covered lives include spouses, dependents, retirees, and COBRA beneficiaries.
PCORI Rules for HRAs, ICHRAs, and Level-Funded Plans
If a plan sponsor offers a stand-alone HRA, one of the methods must be used to count the average number of covered lives. If the HRA is integrated with an insured plan, the plan sponsor will be responsible for a separate PCORI fee on the HRA-covered lives, even though the insurer will pay for the covered lives under the insured plan. Plan sponsors of an HRA integrated with a non-account self-insured plan will not have to pay separately on the self-insured plan and HRA.
Note for HRA plan sponsors: When counting covered lives for the PCORI fee, employers count only the employee/participant, spouses and dependents are not counted for HRA purposes.
Note for ICHRA and QSEHRA plan sponsors: ICHRAs and QSEHRAs are also subject to PCORI fees. For level-funded plans, the Third-Party Administrator (TPA) may assist with data collection and calculations; however, the plan sponsor is solely responsible for the PCORI filing and payment of fees – confirm your arrangement with your TPA before the July 31 deadline.
If you need additional support, OneDigital's team of Employee Benefits Consultants can help you streamline reporting and ensure your organization always remains compliant.