By Mark Adams
Under the Internal Revenue Service’s recently released Notice 2025‑61, the PCORI fee applicable to health‑plan years ending on or after October 1, 2025 and before October 1, 2026 has been set at $3.84 per covered life. For plan years ending in the earlier part of 2025 (January through September), the rate remains $3.47 per covered life. Importantly, the fee continues to apply for most group health plans through plan years that end before October 1, 2029. Employers sponsoring self‑insured plans must file IRS Form 720 and remit payment by July 31 of the calendar year following the end of the plan year. For example, a calendar‑year plan ending December 31, 2025, will have this fee due by July 31, 2026.
For employers, the key take‑aways are three‑fold. First, verify the type of health coverage your organization sponsors: if you have a fully‑insured major medical plan, the insurer typically pays the PCORI fee and you won’t be responsible directly, but if you sponsor a self‑insured or level‑funded plan (or an HRA or ICHRA that triggers reporting), you must ensure filing and payment. Second, accurately calculate the “average number of covered lives” for your plan year — you can use the Actual Count, Snapshot or Form 5500 method — and be sure to account for dependents, retirees and COBRA participants as required (for more information on how these counting methods for determining the average number of covered lives – you can refer to the final regulations here). Third, treat this requirement as a compliance checkpoint: missing or underpaying the PCORI fee can result in penalties and interest, and even though the individual dollar amount might seem modest per covered life, the aggregate exposure and administrative oversight (especially if multiple plan years or short plan years are involved) can be material.