PCORI Fee for Non-Calendar Plan Years

A fiscal year plan pays the PCORI fee on the same basis as any other plan. Everything turns on one date: the last day of the plan year. That date sets both the rate and the due date. A plan year ending June 30, 2026 uses $3.84 and is due in 2027, on Monday, August 2, not in July 2026.

Non-calendar plans get this wrong in predictable ways, since two different clocks are involved. This article shows how they work and gives you a table for each plan year end. Once you have your line, you can report the PCORI fee on Form 720.

Why a fiscal year plan runs on two different clocks

The rate and the due date don't follow the same calendar.

• The rate follows the federal fiscal year. It runs October 1 through September 30. The regulation sets each applicable dollar amount by the federal fiscal year in which the plan year ends.
• The due date follows the calendar year. The fee is due July 31 of the calendar year after the plan year ends.

So one October-to-September rate band spans two filing years. A plan year ending in October, November, or December 2025 uses $3.84 and is due in 2026. A plan year ending between January and September 2026 also uses $3.84, but is due in 2027.

PCORI rate and due date by plan year end

This table covers plan years ending in each month of 2026, which are the ones most fiscal-year sponsors will report next.

The August 2 date exists because July 31, 2027 is a Saturday. The Form 720 instructions let you file on the next business day when a due date lands on a weekend.

For the years on either side:

Why a June 30, 2026 plan year uses $3.84 and is due in 2027

The company and numbers are made up. A manufacturer sponsors a self-insured plan with a plan year of July 1, 2025 through June 30, 2026. Its average is 640 covered lives.

1. Rate. June 30, 2026 is on or after October 1, 2025 and before October 1, 2026, so the rate is $3.84.
2. Fee. 640 x $3.84 = $2,457.60.
3. Year it is due. The plan year ended in calendar 2026, so the fee is due in calendar 2027.
4. Date. July 31, 2027 is a Saturday, so the manufacturer may file on Monday, August 2, 2027.

Here are the two wrong answers we'd expect to see for this plan:

• "It started in 2025, so use $3.47." The rate follows the end date, not the start date. A plan year starting July 1, 2025 and ending June 30, 2026 doesn't touch the $3.47 band.
• "It ended June 30, 2026, so it was due July 31, 2026." That date fell in the same calendar year the plan year ended. The fee is due in the following calendar year, about 13 months after this plan year ended.

Try your own number in the PCORI fee calculator. If your plan year ends from October 1, 2025 through September 30, 2026, the rate is $3.84.

What else changes for a non-calendar plan?

The line on the form. On the June 2026 revision, self-insured plans use line 133(c) at $3.47 and line 133(d) at $3.84. Each is labeled by when the plan year ends. Use the most current revision when you file, since the IRS updates the form each year. Our article on line 133 has more.

The quarter. You still file the second-quarter Form 720. A June 30, 2026 plan year goes on the second-quarter 2027 return. It does not go on a return for a quarter that matches your plan year end. If you pay through EFTPS, the IRS says to apply the payment to the second quarter.

The counting periods. The actual count method uses the days in your plan year. The snapshot method uses quarters of the plan year, so a July-to-June plan's first quarter runs July through September. The Form 5500 method requires that the Form 5500 for the plan year be filed by the fee's due date. See our guide to counting covered lives.

A change of plan year. Moving to or from a calendar year creates a short plan year, which has its own fee and due date under IRS Q&A 12 to 14.

Insurers. Issuers with non-calendar policy years use the rate and due-date rule in the same way. Their line is 133(a) or 133(b) on the June 2026 form, and the regulation has further rules for issuers using the member months or state form methods.

Filing a fiscal year plan online

Because a fiscal plan's return is due so long after the plan year ends, the first risk is simply forgetting it. Note the due date when the plan year closes, and finish your count while the enrollment records are still easy to pull.

When it's time, you can file your PCORI fee online with EasyFile720, an IRS-authorized e-file provider. Creating an account is free with no credit card, and you pay $39.95 when you file. You enter your business details and average covered lives. The rates for the return are built in, the math is calculated for you, and validations catch common mistakes before you submit. You sign electronically and get an electronic acknowledgment from the IRS once it's accepted. Past returns are saved in your account, which makes next year's filing easier to check against this one.

FAQ

Sources: IRS PCORI Questions and Answers; Instructions for Form 720 (Rev. June 2026); Form 720 (Rev. June 2026); 26 CFR 46.4376-1; 26 CFR 46.4377-1. General information, not tax advice. Confirm how the rules apply to you with a qualified advisor or the IRS.