Missed PCORI Fees for Prior Years
Say you took over benefits and found that a self-funded plan has no PCORI filings for the past few years. The fix is one return per missed year, each at that year's rate. A plan year goes on the second-quarter Form 720 of the year after it ended. Late PCORI fees don't get combined into one catch-up filing, and the current $3.84 rate doesn't apply backward.
First, make sure you really missed something. If the plan was fully insured in those years, the insurer was the responsible party, not you. The fee falls on you for years when you sponsored a self-insured plan, including an HRA that doesn't qualify as an excepted benefit.
What rate applies to each missed year?
IRS Q&A 3 sets the rate by the date the plan year ended. These are the published amounts:
| Plan or policy year ended | Rate per covered life |
|---|---|
| Oct 1, 2025 to Sep 30, 2026 | $3.84 |
| Oct 1, 2024 to Sep 30, 2025 | $3.47 |
| Oct 1, 2023 to Sep 30, 2024 | $3.22 |
| Oct 1, 2022 to Sep 30, 2023 | $3.00 |
| Oct 1, 2021 to Sep 30, 2022 | $2.79 |
| Oct 1, 2020 to Sep 30, 2021 | $2.66 |
| Oct 1, 2019 to Sep 30, 2020 | $2.54 |
| Oct 1, 2018 to Sep 30, 2019 | $2.45 |
| Oct 1, 2017 to Sep 30, 2018 | $2.39 |
| Oct 1, 2016 to Sep 30, 2017 | $2.26 |
| Oct 1, 2015 to Sep 30, 2016 | $2.17 |
| Oct 1, 2014 to Sep 30, 2015 | $2.08 |
| Oct 1, 2013 to Sep 30, 2014 | $2.00 |
| Oct 1, 2012 to Sep 30, 2013 | $1.00 |
For a calendar-year plan, that maps to the returns below. A fiscal-year plan follows the same logic: find the rate by the end date, then use the July deadline in the following calendar year. Due dates that fell on a weekend moved to the next business day, under the rule in the instructions.
| Calendar plan year | Rate | Return quarter ending | Original due date | E-file rule allows it? |
|---|---|---|---|---|
| 2025 | $3.84 | June 2026 | July 31, 2026 | Yes |
| 2024 | $3.47 | June 2025 | July 31, 2025 | Yes |
| 2023 | $3.22 | June 2024 | July 31, 2024 | No |
| 2022 | $3.00 | June 2023 | July 31, 2023 | No |
| 2021 | $2.79 | June 2022 | August 1, 2022 | No |
| 2020 | $2.66 | June 2021 | August 2, 2021 | No |
| 2019 | $2.54 | June 2020 | July 31, 2020 | No |
Why can't older years be e-filed?
IRS e-file business rule F720-210-04, in the 2026 Q4 publication, says that if line 133 has a non-zero amount, the quarter ending in the return header must be 2025-06 or 2026-06. Anything else is set to reject. The window moves over time: the earlier version of the rule, now marked deleted, allowed 2024-06 and 2025-06.
That leaves paper for older years. It isn't a lesser option, since the IRS says electronic filing of Form 720 for this fee is available but not required. The June 2026 instructions list the Ogden, Utah, address under "Where To File." Check the current instructions for the address before you mail anything.
How do you count lives for years that have passed?
Self-insured plan sponsors have three methods: actual count, snapshot, and Form 5500. Our covered lives guide gives an overview. A few rules matter more when you are working backward:
- Each year stands alone. The regulation requires the same method throughout a plan year but allows a different method the next year. Use whichever one your records support for that year.
- The Form 5500 method depends on the Form 5500 date. The form must have been filed no later than the fee's due date for that plan year. If it was, you may be able to use it even though the PCORI return itself is late.
- One older window is looser. The IRS PCORI page says that for plan years ending on or after October 1, 2019, and before October 1, 2020, sponsors may use any reasonable method, applied consistently for the plan year.
- COBRA and retiree lives count. Q&A 6 is clear on this, so include them when you rebuild old enrollment.
- Short plan years still count. A plan that started midyear owes the fee for that first short year, due July 31 of the following calendar year.
Example: three missed calendar years
A made-up company with a self-insured calendar-year plan discovers it never filed for 2022, 2023, or 2024.
| Plan year | Average lives | Rate | Fee | Return quarter ending |
|---|---|---|---|---|
| 2022 | 95 | $3.00 | $285.00 | June 2023 |
| 2023 | 102 | $3.22 | $328.44 | June 2024 |
| 2024 | 110 | $3.47 | $381.70 | June 2025 |
| Total | $995.14 | Three separate returns |
Penalties and interest may be added on top of the $995.14. Only the 2024 plan year falls in the e-file window under the current rule. The PCORI fee calculator is a quick way to check each year's multiplication.
What should you do now?
- List every plan year you sponsored a self-insured plan, including any HRA, and note each end date.
- Match each year to its rate and return using the tables above.
- Pull your enrollment records and pick a counting method for each year.
- Check whether you already filed a Form 720 for that quarter for another tax. If so, the fix is Form 720-X, since the IRS wants only one Form 720 per quarter.
- File and pay. Pub. 510 lists late filing and late payment among the acts that can bring penalties and interest, so the amounts may grow while you wait. See what late filing can cost.
If you get a penalty notice later, the instructions say to reply to it with an explanation, and the IRS will determine whether you meet reasonable-cause criteria. We can't tell you what the outcome will be.
EasyFile720 is an IRS-authorized e-file provider, so it works within the same IRS limits described above. Before you commit to anything, you can create an account for free with no credit card and confirm the period you need is offered. You pay only when you file: $39.95 per filing, or $139.99 per business for the Full Year Plan with 4 filing credits that never expire. After you have caught up, the PCORI fee filing page shows how to stay current. The next PCORI deadline, for plan years that end in 2026, is Monday, August 2, 2027, because July 31, 2027 is a Saturday. The IRS publishes the rate for plan years ending on or after October 1, 2026, so check the second-quarter 2027 instructions. When you are ready for that return, you can file the fee online.
FAQ
Can I put all my missed PCORI years on one Form 720?▼
No. The fee for a plan year is reported on the second-quarter Form 720 for the following calendar year, so plan years ending in different calendar years go on different returns. Only plan years that ended in the same calendar year share a return.
Do I use today's $3.84 rate for an old year?▼
No. The rate is set by when the plan year ended. A calendar 2021 plan year uses $2.79, for example, whenever you actually file.
I filed a second-quarter Form 720 that year for another excise tax. What now?▼
The IRS says only one Form 720 should be filed for each quarter, so the missing fee is a correction to a return you already filed. Corrections to a previously filed Form 720 go on Form 720-X.
Should I explain why I am late when I file?▼
The Form 720 instructions say not to include an explanation with the return. If you receive a penalty notice afterward, reply to that notice with your explanation.
File your PCORI fee online
Create a free account with no credit card and build your return. You pay $39.95 only when you file. EasyFile720 is an IRS-authorized e-file provider, and you get an acknowledgment when the IRS accepts your return.
Sources: IRS PCORI Questions and Answers (Q3, Q8, Q13, Q14, Q16); IRS PCORI fee page; Form 720 and Instructions for Form 720 (Rev. June 2026); IRS e-file Business Rules 2026Q4v1.0 (F720-210-03, F720-210-04); 26 CFR 46.4376-1; Pub. 510 (Rev. December 2025). General information, not tax advice. Confirm how the rules apply to you with a qualified advisor or the IRS.
