PCORI Fees Due July 31, 2026

The Affordable Care Act (ACA) requires self-funded plan sponsors and health insurance issuers to pay Patient-Centered Outcomes Research Institute (PCORI) fees. This is also sometimes referred to as Comparative Effectiveness Research Fees, or CERFs. The fees are reported and paid annually using IRS Form 720 (Quarterly Federal Excise Tax Return).

For plan years ending in 2025, PCORI fees are due by July 31, 2026.

Who Must File and Pay

• Insurers are responsible for fully insured medical plans.
• Employers are responsible for self-funded plans, including level-funded plans and health reimbursement arrangements (HRAs), such as ICHRAs and QSEHRAs.

Calculating the PCORI Fee Payment

The PCORI fee is based on the average number of covered lives during the plan year, multiplied by the applicable dollar amount. Applicable fee amounts are as follows:

• $3.47 per covered life for plan years ending on or after October 1, 2024, and before October 1, 2025
• $3.84 per covered life for plan years ending on or after October 1, 2025, and before October 1, 2026 (for the 2026 filing, it will be plan years ending no later than December 31, 2026)

Employers with self-funded plans may use one of the following methods to calculate average covered lives:

• Actual Count Method
• Snapshot Method (including Snapshot Factor Method)
• Form 5500 Method (available only if eligibility requirements are met)

Additional Guidance

The IRS provides helpful resources, including a chart on how the fees apply to different types of coverage and arrangements.

If you have questions about whether your plan is subject to PCORI fees or how to calculate and file them, please reach out to your Hylant representative for further information. Don’t have one? Contact us here.

The above information does not constitute advice. Always contact your employee benefits broker or trusted advisor for insurance-related questions.