PCORI Fee (Form 720)

The PCORI fee applies to plan years ending before October 1, 2029 (extended by Pub. L. 116-94). If you pay via EFTPS, select Q2 for the quarter under Tax Period. No quarterly deposits are required.

• Plan inventory: A complete list of all health plans and HRAs you sponsor, with plan type (self-insured medical, HRA, ICHRA, QSEHRA, EBHRA) and plan year start/end dates for each. Confirm EBHRA status for any excepted benefit HRA.
• Covered-lives data: Enrollment records for each subject plan: daily counts (Actual Count method), quarterly snapshot dates (Snapshot method), or prior-year Form 5500 participant data (Form 5500 method). Include employees, dependents, retirees, and COBRA participants.
• Carrier confirmation: Written confirmation that your insurer is paying PCORI for any fully insured medical plan. This is your documentation that you don't owe on that plan.
• EIN and payment setup: Your employer EIN for Form 720; EFTPS enrollment if paying electronically (optional; check or money order are also accepted).
• Prior year Form 720: For reference on counting method used and to maintain consistency year over year.

• Electronic filing: Available but not required for PCORI. IRS-approved e-file providers are listed at IRS.gov/e-file-providers.
• Paper filing: Mail the completed Form 720 (current revision) with payment to the address in the Form 720 instructions.
• Payment method: Check (payable to United States Treasury), EFTPS (select Q2, Tax Period: 2nd Quarter), or other IRS business payment options. No deposits are required; payment is due with the return on July 31.
• Quarterly filing note: If PCORI is your only Form 720 liability, you only file once a year: the Q2 return due July 31. You are not required to file for Q1, Q3, or Q4.
• Corrections: File Form 720-X (Amended Quarterly Federal Excise Tax Return) to correct a previously filed Form 720. Do not reduce the following year's PCORI fee by a prior year overpayment; use Form 720-X instead.

• Copy of the filed Form 720Current year and prior years for reference.
• Covered-lives calculation worksheetsShowing the counting method used, the data sources, and the calculation steps for each subject plan.
• Plan documentsConfirming plan type and plan year dates for each plan included (or excluded) from the calculation.
• Carrier confirmationWritten confirmation from your carrier that PCORI is being paid on any fully insured medical plan.
• Payment confirmationEFTPS transaction record, canceled check copy, or other proof of payment.

Common traps

FAQs

Do COBRA participants and retirees count as covered lives?

Yes. All individuals covered during the plan year, including active employees, dependents, COBRA continuants, and retirees, must be counted in your average covered lives calculation.

My plan year ends June 30, not December 31. What rate applies and when do I file?

The rate depends on the month your plan year ends. A plan ending June 30, 2026 falls in the "Oct 1, 2025 - Sept 30, 2026" window (rate is $3.84 per covered life) and the return is due July 31, 2026. Check the IRS rates table (linked in Official Guidance) for your specific plan year end month.

We have both a self-insured medical plan and an HRA. Do we file PCORI for both?

It depends. If both have the same plan year and the same plan sponsor, you may treat them as a single applicable self-insured health plan and count covered lives once (the anti-duplication rule). If the plan years differ or if the HRA is sponsored by a different entity, they are counted separately. See Special Cases for more detail.

Is the PCORI fee tax-deductible?

Yes. The PCORI fee is deductible as an ordinary and necessary business expense under IRC Section 162.

• IRS: PCORI Fee Overview (background, who owes, how to file, and links to related guidance)
• IRS: PCORI Filing Due Dates and Applicable Rates (current and prior year rates by plan year end month)
• IRS: PCORI Fee Questions and Answers (counting methods, exceptions, HRA rules, corrections)
• IRS: Application of PCORI Fee to Common Plan Types (chart of which arrangements are and are not subject)
• IRS: About Form 720 (current form, instructions, and recent updates)
• IRS: About Form 720-X (amended return for corrections to a prior Form 720)

• HRA alongside fully insured medical: The carrier pays PCORI on the insured medical plan. For your HRA, count one covered life per HRA participant; do not count dependents. This prevents double-counting with the carrier's payment on the medical plan.
• HRA alongside self-insured medical (same plan sponsor, same plan year): You may treat them as a single applicable self-insured health plan and run one covered-lives count. This avoids double-counting an employee as both a medical plan participant and an HRA participant. If plan years differ or the HRA is under a separate EIN, count them separately.
• ICHRA and QSEHRA: Both are HRAs and are subject to PCORI. Count one covered life per participating employee (since these arrangements reimburse individual insurance rather than covering dependents directly under the HRA). See the ICHRA and QSEHRA pages.
• Short plan years: PCORI applies to short plan years; a newly established plan or a plan changing its plan year will have a period shorter than 12 months. Calculate average covered lives for the actual short period and pay the full applicable rate; the fee is still due July 31 of the following year.
• Multiple self-insured plans with the same EIN: Report each plan separately in Part II of the same Form 720 and total the fees. Different EINs must file separate Form 720s.
• No state analog: PCORI is a federal fee only; there is no state-level equivalent.

★Quick-reference table for common health plans and arrangements. When in doubt about a specific arrangement, confirm with the IRS application chart (linked in Official Guidance).