After a week of waiting, the IRS republished its second quarter Form 720, resolving the availability gap that began last week. For a quick timeline, the IRS updated the form on 6/26 with the new PCORI fee rates, then pulled it from their website on 6/30 while they made corrections to Lines 11a through 11f. As of the morning of July 7, 2026, the 720 form is again available on the IRS website.
For those who already filed using the interim version (the copy that was briefly available between June 26 and June 30), there should be no need to refile or take any corrective action. The only change between that version and today's release involves the overpayment election in Part III (how a filer indicates whether an overpayment should be applied to the next return or refunded), which has no bearing on the PCORI fee amounts or calculations themselves. Those figures ($3.47 and $3.84 per covered life, depending on plan year) were correct in the interim version and remain unchanged.
Employers and other plan sponsors who were waiting for the newest version are now encouraged to complete and submit their Form 720 for PCORI fees ending in 2025 before the July 31, 2026 deadline (when applicable).
Who this applies to:
- Self-funded medical plans ending in 2025, including level-funded plans, HRAs, ICHRAs, QSEHRAs, MERPs, and other less common arrangements as described on the IRS chart.
- Fully insured plans are the carrier’s responsibility to file and pay.
- Exceptions: Excepted benefits are exempt, including stand-alone vision or dental plans, HSAs, and health FSAs that qualify as an excepted benefit.
Key details:
For more information about PCORI fees, view these documents: PCORI Fee Basics and PCORI Fee Calculation Methods. For a walkthrough on completing and filing the Form 720, see PCORI Fee Form 720 Completion and Submission.
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