Reminder: PCORI Fees Due July 31, 2026 

Employers that sponsored self-funded medical plans ending in 2025 must report and pay Patient-Centered Outcomes Research Institute (PCORI) fees by July 31, 2026.

Who must file: 

• Self-funded plan sponsors are responsible for filing and payment
• Fully insured plans are handled by carriers.
• Employers with HRAs or other self-funded components must file for those portions.

2026 Fee Amounts: 

• $3.47 per covered life (plan years ending October 1, 2024–September 30, 2025) Fully insured plans are handled by carriers.
• $3.84 per covered life (plan years ending October 1, 2025–September 30, 2026) 

Counting Methods: 

Employers may use the actual count, snapshot, or Form 5500 method, with special rules for multiple plans or integrated HRAs. 

How to File: 

PCORI fees are reported and paid using IRS Form 720 (PDF). 

Employers with self-funded plans or HRA components should begin preparing now to ensure timely filing and payment. 

ACA Employer Mandate Penalties Increasing for 2027 

The IRS has released Revenue Procedure 2026-22, updating the inflation-adjusted employer shared responsibility (ESRP) penalties under the ACA employer mandate. 

For the 2027 calendar year, penalty amounts will increase to: 

• $3,780 per full-time employee (up from $3,340 in 2026) 
• $5,670 per affected employee (up from $5,010 in 2026) 

These penalties apply to Applicable Large Employers (ALEs) that either:

• Fail to offer minimum essential coverage, or
• Offer coverage that is not affordable or does not provide minimum value. 

The annual increases are driven by the ACA’s premium adjustment percentage, which reflects growth in private health insurance premiums relative to 2013 baseline levels.  

Employers should review affordability and coverage offerings now to help mitigate potential penalty exposure for the 2027 plan year.

Reminder: Form 5500 Filing Due July 31 

Employers sponsoring health plans with 100 or more participants must file IRS Form 5500 annually by the last day of the seventh month following the end of the plan year. For calendar year plans, the filing deadline is July 31. 

• Who must file: Plan administrators of applicable employee benefit plans 
• Extension available: Employers may file for an automatic extension, moving the deadline to October 15 

Employers should confirm filing status and coordinate with vendors or advisors to ensure timely submission. 

Holiday Closures

Please note our offices will be closed in observance of the following holidays on: 

• Friday, June 19, 2026 (Juneteenth) 
• Friday, July 3, 2026 (Independence Day (observed))