Does This Pertain to You?
If you administer a QSEHRA or ICHRA with a plan year ending in 2025, you must file Form 720 (Quarterly Federal Excise Tax Return) and pay the PCOR fee (Patient‐Centered Outcomes Research Trust Fund) by July 31, 2026.
What To Do
Important note as of June 12, 2026:
The final Form 720 currently posted by the IRS appears not to include the updated PCOR fee line for plan years ending on or after October 1, 2025. IRS rate guidance separately states that the $3.84 rate applies to plan years ending October 1, 2025 through September 30, 2026. Because the updated Form 720 has not yet been released as a final form, our current recommendation is to wait until the IRS releases the final updated Form 720 before filing, as long as you file by the July 31, 2026 deadline.
Download Form 720
- Get the latest second-quarter Form 720 here:
Form 720 (Quarterly Federal Excise Tax Return)
Select the Correct Rate
- Row (c): Plan year ending Jan 1 – Sep 30, 2025 → $3.47 per covered life
- Row (d): Plan year ending Oct 1 – Dec 31, 2025 → $3.84 per covered life
Calculate Your Average Covered Lives
Use the Actual Count Method:
- Add the total number of lives covered on each day of your plan year, then divide by the number of days in that plan year.
- Example: 36,500 daily lives ÷ 365 days = 100 average covered lives.
Complete Form 720
- Enter your average lives in Column (a), using the appropriate Row.
- Multiply Column (a) by Column (b), to calculate your fee in Column (c).
Submit Your Payment
- Include the payment voucher Form 720-V with Form 720 and a check or money order payable to
Department of the Treasury
Internal Revenue Service
Ogden, UT 84201-0009
Sean Grettum
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Sean Grettum
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