Updated April 2026 · Florida Plan Finder · Licensed Florida Health Insurance Producer

IRS Form 720 PCORI Fee Filing for Florida Small Business Health Plans

The Patient-Centered Outcomes Research Institute (PCORI) fee is a small annual federal fee imposed on self-insured health plans to fund comparative-effectiveness research. Florida small businesses with fully-insured group health plans don't file directly — the carrier handles it as part of premium. But businesses with self-funded plans, level-funded plans, or any HRA (including ICHRA, QSEHRA, EBHRA, and integrated HRAs) must file Form 720 each year and pay the fee directly. Missing the July 31 deadline triggers IRS interest and penalties.

PCORI Fee Amount

The fee per covered life depends on the plan year ending date:

Plan Year EndingFee per Covered Life
October 2024 – September 2025$3.47
October 2025 – September 2026$3.47 (subject to annual adjustment)

The fee adjusts annually based on the Federal Per Capita National Health Expenditures inflation factor. IRS publishes the new rate in spring of each year.

Who Must File

Plan TypeWho Pays PCORI Fee
Fully insured group healthCarrier (employer not directly responsible)
Self-funded group healthPlan sponsor (employer)
Level-funded planPlan sponsor (employer) — even though it feels like fully insured
QSEHRAEmployer files
ICHRAEmployer files
Integrated HRAEmployer files (separate from carrier's filing on the underlying plan)
EBHRA (Excepted Benefit HRA)Exempt — no PCORI fee
Retiree-only HRAExempt
Standalone dental/visionExempt

Deadline and Form

The PCORI fee is reported on IRS Form 720 (Quarterly Federal Excise Tax Return), specifically Part II line 133. The annual fee is due by July 31 following the plan year end. A calendar-year plan that ended December 31, 2025 files by July 31, 2026.

Form 720 can be filed electronically (recommended) or by paper. Payment can be made via EFTPS or with the form.

Counting Covered Lives

Florida small businesses can use one of three counting methods:

  1. Actual count method: sum the covered lives for each day of the plan year, divide by days in the plan year
  2. Snapshot method: count covered lives on a fixed date each quarter, average the counts
  3. Form 5500 method: use participant counts from Form 5500 (only if Form 5500 is required for the plan)

For an HRA, "covered lives" = the participating employees only (NOT spouses or dependents). For a self-funded health plan, "covered lives" = all enrolled employees plus enrolled spouses and dependents.

Worked Example: Florida Business with 12-Employee ICHRA

ItemValue
Average covered employees in plan year12
Fee per covered life (2025-2026 plan year)$3.47
Total PCORI fee due$41.64
Form 720 deadlineJuly 31, 2026

Frequently Asked Questions

My carrier sent me a PCORI invoice — do I still file Form 720?

If you have a fully-insured plan, the carrier files and pays — no Form 720 from you. If you have a level-funded plan, despite the carrier handling many other functions, the PCORI fee is YOUR responsibility. Read the plan documents carefully or ask the broker.

What's the penalty for missing the July 31 deadline?

Late filing/payment incurs IRS interest plus a 5% per month failure-to-file penalty (capped at 25%) and 0.5% per month failure-to-pay penalty. For a small fee amount ($30-$200 typical for a small ICHRA), the late penalty often exceeds the fee. File on time.

Does the PCORI fee apply to standalone dental or vision?

No — PCORI applies only to plans providing 'specified health insurance' (medical care). Standalone dental, vision, accident, disability, AD&D, and excepted benefits like the EBHRA are exempt.

Stay Compliant with PCORI Filing on Your Florida Small Business HRA

A licensed Florida broker can confirm whether your plan triggers Form 720 and help with the filing.

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PCORI fee rules are governed by IRC Section 4376. Consult a tax professional for filing assistance.