If you sponsor a self-funded health plan or HRA, the annual PCORI fee deadline is on the horizon. Here’s what you need to know, including why filing too early could actually cost you.
What Is the PCORI Fee?
The Patient-Centered Outcomes Research Institute (PCORI) fee is an annual excise tax that helps fund comparative clinical effectiveness research. Employers sponsoring certain self-funded health plans must file and pay this fee each year by July 31 using IRS Form 720.
For plan years ending in 2025, the deadline is July 31, 2026.
Who Has to Pay It?
PCORI fees apply to employers sponsoring:
- Self-funded health plans (including level-funded plans) with plan years ending in 2025
- Health Reimbursement Arrangements (HRAs)
- Individual Coverage HRAs (ICHRAs)
Fully insured plans: The carrier handles the PCORI fee for the medical plan itself — but if you have an HRA integrated with a fully insured plan, the employer is still responsible for the PCORI fee on the HRA.
How Is the Fee Calculated?
The fee is based on the average number of covered lives enrolled during the plan year, multiplied by the applicable rate for that year. For 2025, the rates are:
| Plan Year-End Date | Fee Per Covered Life |
| Prior to October 1, 2025 | $3.47 |
| On or after October 1, 2025 | $3.84 |
You can start pulling your average enrollment counts now to get a head start — but don’t file just yet.
Why You Should Wait to File
Here’s where many employers trip up: IRS Form 720 is updated throughout the year to reflect changes across many different excise taxes, not just PCORI. A form with a Q2 revision date doesn’t automatically mean the PCORI-specific lines have been updated.
Before filing, check Line 133 on the form:
- Line 133(c) must show $3.47
- Line 133(d) must show $3.84
‼️If those lines still show $3.22 and $3.47 respectively, the form has not yet been updated for 2025, and filing on the old version can result in IRS penalties and interest.
When Will the Form Be Ready?
Historically, the IRS updates Form 720 with the current-year PCORI figures in May, but in some years, the update has not come until early or mid-June.
👉 Our recommendation: Mark your calendar for mid-June 2026, then check Line 133 before proceeding. Once the 2025 figures appear, you’re clear to file and pay, with plenty of time before the July 31 deadline.
Your PCORI Checklist
✅ Confirm whether your plan is subject to PCORI fees (self-funded, level-funded, HRA, or ICHRA)
✅ Calculate your average enrollment count for the 2025 plan year
✅ Determine the applicable rate ($3.47 or $3.84) based on your plan year end date
✅ Wait for the updated IRS Form 720 — confirm Line 133(c)/$3.47 and Line 133(d)/$3.84 before filing
✅ File and pay by July 31, 2026
Have questions about your PCORI obligations or need help calculating your enrollment counts? Reach out to your BSI benefits advisor — we’ll make sure you’re filing at the right time, with the right form.