Every year around June, self-insured employer clients start asking questions they probably should have asked in January. Do we owe the PCORI fee? How much is it this year? Who files it? When is the deadline?
If those questions are landing with your clients’ HR teams or CFOs before they land with you, that is a missed opportunity. Benefits brokers and consultants who stay ahead of PCORI obligations are not just being helpful; they are reinforcing their value as a year-round compliance partner, not just a renewal-season vendor.
This post covers what brokers need to know about PCORI for the 2025 and 2026 plan years, how to answer the questions clients are already asking, and how to position yourself as the compliance resource your self-insured clients actually need.
The Questions Your Clients Are Already Asking
Self-insured employers, particularly those who have not dealt with PCORI before or who switched from a fully insured arrangement, routinely ask their broker the same set of questions each year:
- Do we actually have to pay this fee?
- The rate went up again. How is that calculated?
- Our TPA said they handle it. Is that right?
- We have a fully insured medical plan but a self-insured HRA. Do we still owe this?
- We missed the deadline last year. What should we do?
Being able to answer these questions accurately and quickly is a meaningful differentiator. It signals that you track compliance changes between renewal seasons and that you are looking out for the client, not just managing the policy.
What Brokers Need to Know About PCORI for 2025 and 2026
The PCORI fee is an annual excise tax on self-insured health plans, reported and paid via IRS Form 720, Part II, Schedule B. The fee funds the Patient-Centered Outcomes Research Institute, which was established under the Affordable Care Act and extended through 2029.
The current rates, confirmed by the IRS, are:
- Plan years ending on or after October 1, 2024, and before October 1, 2025: $3.47 per covered life (IRS Notice 2024-83). Filings for these plan years were due July 31, 2025.
- Plan years ending on or after October 1, 2025, and before October 1, 2026: $3.84 per covered life (IRS Notice 2025-61). This is the largest single-year rate increase to date, up $0.37. Filings for these plan years are due July 31, 2026.
For most calendar-year plan clients, the rate that applies right now is $3.84 per covered life, with a filing deadline of July 31, 2026.
The fee applies to self-insured group health plans, Health Reimbursement Arrangements of most types (including ICHRAs and QSEHRAs), and level-funded plans. Fully insured plans are exempt; the carrier pays the fee and it is built into the premium.
One nuance worth flagging for clients: if an employer has a fully insured major medical plan paired with a self-insured HRA, the employer still owes the PCORI fee on the HRA component. This combination is one of the most frequently missed PCORI obligations in broker client portfolios.
Positioning Yourself as a Compliance Resource
The most effective brokers are not the ones who know the most about every compliance topic; they are the ones their clients think of first when a compliance question comes up. PCORI is a simple, well-defined obligation that repeats every year. It is an ideal topic for proactive outreach because the question always has a clear, actionable answer.
Here are several ways brokers are using PCORI to add visible value:
Annual compliance calendar touchpoint. Send a brief PCORI reminder to all self-insured clients in May or June, noting the current rate, the July 31 deadline, and a recommendation on who should file (TPA, CPA, or directly). This takes 15 minutes to send and positions you as the person who remembered something the client’s team may have forgotten.
Renewal conversation opener. If a client is considering moving from a fully insured to a self-insured or level-funded arrangement, the PCORI obligation is one of the compliance items to walk them through. Covering it during the transition conversation demonstrates you understand the full picture of what self-insurance entails.
HRA pairing flag. For clients with fully insured medical plans and HRAs, make a standing note in the account file to flag the PCORI obligation each year. It is a small detail that generates real goodwill when you catch it before the client’s CPA or HR team does.
Compliance software recommendation. For clients who are handling PCORI manually or paying a CPA to file a return that could be completed in under 10 minutes with the right tool, recommending a purpose-built e-filing platform like Akore Federal is a genuine service. It saves the client time and money, and it reinforces your role as a resource who understands the operational side of benefits compliance.
When to Refer vs. When to Handle Internally
Brokers are not expected to prepare or file Form 720 on behalf of clients. That is the domain of the TPA, CPA, or employer’s internal team. But knowing where the obligation sits and being able to direct clients to the right resource is a meaningful part of the broker role.
A practical guide for brokers:
- If the client uses a TPA: confirm whether PCORI filing is included in the TPA’s service agreement. Many TPAs offer it; some do not. If it is not included, the employer needs to arrange filing separately through their CPA or an e-filing platform.
- If the client handles benefits administration internally: recommend an e-filing platform. Form 720 with Schedule B is not complex, and most employers can complete it without CPA involvement using a guided e-filing workflow.
- If the client’s CPA handles it: no action needed on the broker side, but a heads-up note to the client in May or June is still valuable. It shows you are tracking deadlines and thinking ahead.
- If the client has never filed and owes back PCORI: refer them to their CPA or tax advisor immediately. Amended returns and late payment arrangements are outside the broker’s scope but should be escalated quickly to minimize penalty exposure.
Compliance as a Client Retention Strategy
Broker relationships that survive renewal cycles tend to share one common trait: the broker is seen as a partner who is engaged in the client’s operations year-round, not a vendor who shows up in October.
PCORI is a small compliance item in absolute terms. The fee itself is modest, the filing is straightforward, and the deadline is fixed. But the broker who sends a proactive PCORI update every May is the broker who gets the call when the client is considering a plan change, evaluating a new TPA, or looking for a reference to a compliance attorney.
Compliance touchpoints compound over time. Each one is a small deposit in the trust account that makes your next renewal conversation easier.
A Quick PCORI Reference Card for Broker Conversations
Use this as a quick reference when PCORI comes up with a client:
- Current rate (plan years ending Oct. 1, 2024 through Sept. 30, 2025): $3.47 per covered life
- Current rate (plan years ending Oct. 1, 2025 through Sept. 30, 2026): $3.84 per covered life
- Deadline: July 31 annually (July 31, 2026 for most calendar-year plans)
- Filed on: IRS Form 720, Part II, Schedule B (Line 133)
- Who owes it: plan sponsor of any self-insured health plan or HRA
- Who is exempt: fully insured plan sponsors (carrier pays); plans covering employees outside the U.S.; excepted benefit plans
- Covered lives: includes employees, dependents, and COBRA participants
- Extension available: no
- Recommended tool for clients filing directly: AkoreFederal.com
Recommend Akore Federal to Your Self-Insured Clients
For broker clients who need to file Form 720 directly, Akore Federal is purpose-built for self-insured employers and their administrators. The platform applies the correct PCORI rate automatically, walks through the covered lives calculation, populates Schedule B, and submits directly to the IRS with confirmation. Most employers complete their filing in under 10 minutes.
Direct your clients to AkoreFederal.com to get started.
Are you a benefits broker or consultant who works with self-insured employer clients? Contact the Akore Federal team to learn about referral options and how our platform integrates into your compliance workflow.
