First-Time PCORI Filing Checklist

Work through this list in order. A first PCORI filing takes six stages: confirm you owe the fee, identify who files, find your rate, count covered lives, complete the form, then file, pay, and keep records. The fee is reported on a second-quarter Form 720, and the next due date is Monday, August 2, 2027.

If you need background first, start with what the PCORI fee is and who it applies to. PCORI stands for the Patient-Centered Outcomes Research Institute, which this fee helps fund. The IRS instructions call it the PCOR fee, and the form lists it as IRS No. 133.

Stage 1: Do you owe it?

Match your coverage to the IRS chart. Stop here if nothing in your organization is subject to the fee.

• Fully insured major medical only: the issuer is responsible, not you. If you have no HRA or other self-insured arrangement, you have no PCORI return to file.
• Self-insured health plan: subject to the fee. The plan sponsor pays and reports.
• HRA, including a premium-only HRA: subject to the fee unless it qualifies as an excepted benefit. The plan sponsor pays and reports, even if the medical coverage alongside it is insured.
• FSA: subject to the fee unless it qualifies as an excepted benefit.
• Retiree-only and COBRA coverage: subject to the fee, with the issuer responsible if insured and the sponsor if self-insured.
• Not subject: stand-alone dental or vision, HSAs, Archer MSAs, stop-loss, disability income, accident-only coverage, workers' compensation, and on-site medical clinics.

Tax-exempt and government employers aren't automatically out. The IRS says those plans are subject to the fee unless they are an exempt governmental program. Our HRA and FSA guide goes deeper on those arrangements.

Stage 2: Who files, and with what ID?

• Confirm the plan sponsor. For a plan set up by one employer, that is the employer.
• Find the sponsor's employer identification number (EIN). If it has none, apply at IRS.gov/EIN, or fax or mail Form SS-4.
• Note the exact name and address the IRS has for that EIN. An e-filed return must match the EIN and name control in the IRS database.
• Identify who is authorized by the entity to sign. If someone outside the business is paid to prepare the return, that person also completes the paid preparer section.

Stage 3: Which rate fits your plan year end?

Only the plan year end date matters here, not the date you file.

For a plan year ending in late 2026, including a calendar 2026 plan, check the second-quarter 2027 instructions for the rate. The IRS says to use the most current Form 720 revision for this filing, and that the updated rates typically come with the revision released in spring. If you already missed a due date, see what happens after a late PCORI filing.

Stage 4: Count average covered lives

1. Pick one method for the whole plan year. A self-insured sponsor generally uses the actual count, snapshot, or Form 5500 method. You may change methods from one plan year to the next.
2. Include everyone who was covered: employees, dependents, retirees, former employees, and COBRA beneficiaries.
3. Apply the special rule if it fits. If your only self-insured arrangement is an HRA or health FSA, you may count one life per participant and leave out spouses and dependents.
4. If two self-insured plans have the same sponsor and the same plan year, you may treat them as one plan, so a person in both counts once.
5. Save the worksheet. You will want it later.

Our average covered lives guide works through each method with numbers.

Stage 5: Complete the Form 720

1. Enter the business name, address, EIN, and a June quarter ending date.
2. In Part II, on the correct IRS No. 133 line, enter the average lives in column (a). The rate is in column (b). Enter the fee in column (c).
3. Enter the combined fee in the Tax column for IRS No. 133.
4. Carry the Part II total into Part III. Line 3 is total tax, and line 10 is the balance due.
5. Skip Schedule A. The form says not to complete it for Part II taxes.
6. Sign, date, and add a title and telephone number.

Stage 6: File, pay, and keep records

• File by e-file, or mail to the Ogden, Utah address in the instructions. E-filing is available but not required.
• Pay by the due date. Options include IRS Direct Pay, EFTPS, card, digital wallet, or a check or money order with Form 720-V. If you pay by EFTPS, apply the payment to the second quarter. No deposits are required.
• Keep copies of the return, your lives worksheet, and proof of payment. The instructions say to keep records that show the correct tax has been paid, and to keep records supporting claims and exemptions for at least 4 years.
• Diary next year's date. If PCORI is your only excise item, skip the first, third, and fourth quarters.

If you would rather not assemble the form by hand, you can file your PCORI fee online with EasyFile720. Creating an account is free, with no credit card needed to start, and you pay $39.95 when you file. The guided steps run from business details through to submission. You enter your covered lives and the rate and math are handled for you. You count the lives and choose the method yourself, so finish Stage 4 first. After you sign electronically and the IRS accepts the return, you get an electronic acknowledgment, and the return stays saved in your account. With this list done, your next step is to create your free account and enter what you have gathered.

FAQ

Sources: Instructions for Form 720 (Rev. June 2026); Form 720 (Rev. June 2026); IRS PCORI Questions and Answers; IRS PCORI coverage chart; 26 CFR 46.4376-1. General information, not tax advice. Confirm how the rules apply to you with a qualified advisor or the IRS.