PCORI and Form 5500 Are Both Due July 31. Here Is Who Owes What.

July 31 is the busiest compliance day of the year for self-funded plans, and it catches fully insured employers too. Here is the short version.

PCORI

The Patient-Centered Outcomes Research Institute fee is paid once a year on Form 720. For plan years ending between October 1, 2025 and September 30, 2026, the rate is $3.84 per covered life. The rate for plan years ending on or after October 1, 2026 has not been published yet.

If you are fully insured, the carrier pays it and builds it into your premium. You do nothing. If you are self-funded, including level-funded arrangements where the plan is technically self-funded, you pay it. The same goes for a health reimbursement arrangement that sits alongside a fully insured plan: the HRA is self-funded, so the employer owes PCORI on it, though usually on employees only rather than every covered life.

Counting covered lives sounds simple and is not. There are three permitted methods, and the one you choose affects what you owe. We walk clients through this each June.

Form 5500

The annual report is due the last day of the seventh month after the plan year ends, which is July 31 for a calendar-year plan. The general rule is that plans with 100 or more participants on the first day of the plan year have to file, and a fully insured or unfunded welfare plan under 100 participants is generally exempt. Count participants, not employees. Dependents do not count; enrolled employees, retirees, and COBRA participants do.

If you have several benefits that sit under one wrap plan document, you file one 5500. If you do not have a wrap document, you may be filing several, and that is a reason to get a wrap document.

The extension is Form 5558, filed by July 31, which moves the deadline to October 15. There is no extension for PCORI.

The penalties

The Department of Labor can assess penalties for late 5500s that run into thousands of dollars per day, and the Delinquent Filer Voluntary Compliance Program is the way to fix a missed year at a much lower cost. If you just realized you should have been filing and were not, use that program before the DOL writes to you.

The Summary Annual Report

Once the 5500 is filed, participants get a Summary Annual Report within two months, so September 30 for a July filing, or December 15 if you extended.

This is general guidance, not legal or tax advice. If you are not sure whether you owe either filing, send us your enrollment count and funding arrangement and we will tell you in a day.