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Employers that sponsor self-insured group health plans, including health reimbursement arrangements (HRAs) should keep in mind the upcoming July 31, 2026 deadline for paying fees that fund the Patient-Centered Outcomes Research Institute (PCORI) via Form 720, which was recently updated and released by the IRS.

The amount of PCORI fees due by employer sponsors and insurers is based upon the number of covered lives under each “applicable self-insured health plan” and “specified health insurance policy” (as defined by regulations) and the plan or policy year end date.  This year, employers will pay the fee for plan years ending in 2025. The fee is due by July 31, 2026 and varies based on the applicable plan year as follows:

•    For plan years that ended between January 1, 2025 and September 30, 2025, the fee is $3.47 per covered life.
•    For plan years that ended between October 1, 2025 and December 31, 2025, the fee is $3.84 per covered life.

For example, for a plan year that ran from July 1, 2024 through June 30, 2025, the fee is $3.47 per covered life. The fee for calendar year 2025 plans is $3.84 per covered life. The insurance carrier is responsible for paying the PCORI fee on behalf of a fully insured plan.  

The employer is responsible for paying the fee on behalf of a self-insured plan, including an HRA.  In general, health FSAs are not subject to the PCORI fee.

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