The IRS recently released Notice 2025-61, setting the Patient-Centered Research Institute (PCORI) fee for plan years ending on or after October 1, 2025 and before October 1, 2026 at $3.84 per covered life. For comparison, the previously announced rate for plan years ending on or after October 1, 2024, and before October 1, 2025, is $3.47 per covered life.
Plans Subject to the PCORI Fee
Employers who sponsored self-insured group health plans, including level funded plans and health reimbursement arrangements (HRAs), must pay the PCORI fee by July 31, 2026.
Background
The annual PCORI fee, created under the Affordable Care Act (ACA), funds research on the effectiveness of medical treatments to help patients, clinicians, and policymakers make informed decisions. Insurance carriers pay the fee for fully insured plans, while employers are responsible for self-insured plans. Originally set to expire in 2019, the fee was extended for 10 years and now applies through 2029.
PCORI Fee Calculations
The PCORI fee is determined by the number of covered lives under each self-insured health plan and the applicable rate per covered life, as summarized below:
PCORI Fee = Rate Per Covered Life x # of Covered Lives Under the Self-Insured Plan
Importantly, the applicable rate per covered life is determined by a plan year’s end date and is increased each year depending on the value of national healthcare expenditures. For the next filing due, employers will pay the fee for self-insured plan years ending in 2025, with rates as follows:
| Plan Year End Dates | PCORI Fee Rate |
| January 2025 through September 2025 | $3.47 per covered life |
| October 2025 through December 2025 | $3.84 per covered life |
For more on the PCORI fee, see the IRS PCORI Fee Q&A.
Employer Action Items
- Employers that only sponsored fully insured plans in 2025 have no action item (insurance carriers are responsible for paying the fee for these plans).
- Employers that sponsored self-insured plans in 2025 (including level funded plans or HRAs) should calculate the PCORI fee, report the fee on IRS Form 720, and pay PCORI fees to the IRS by July 31, 2026.
Employers that only sponsored fully insured plans in 2025 have no action item (insurance carriers are responsible for paying the fee for these plans).
Additional Resources
Connect with a Sequoia consultant to learn how Sequoia’s compliance services are integrated in our benefits services and tailored solutions. And if you’re already a Sequoia client, stay on top of your employer obligations with your Compliance Checklist that highlights important compliance dates, action items, and resources.
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