Filing PCORI for an HRA: Step by Step

If your company has an HRA and it isn't an excepted benefit, your company owes the PCORI fee on it and files Form 720 once a year. For most employers whose only self-insured plan is the HRA, the count is simple: one covered life per participating employee. Average that over the plan year, multiply by the rate, and report it on the self-insured line.

An HRA, or health reimbursement arrangement, is an employer-funded account that repays employees for medical costs. This guide is for the employer who has one and needs to get the return done. For background on how HRAs and FSAs are treated, see our article on the PCORI fee for HRAs and FSAs. If you're ready, you can file the PCORI fee online once you have your number.

Step 1: Check whether your HRA owes the fee

The IRS chart says an HRA, including a premium-only HRA, is subject to the fee "unless the arrangement satisfies the requirements for being treated as an excepted benefit." Excepted benefits are limited kinds of coverage the tax code treats differently. The chart doesn't spell out that test, so if you're unsure, ask your HRA vendor or benefits adviser and keep the answer in your records.

The plan sponsor files, not the HRA vendor. For a single-employer HRA, that is the employer. Paying a vendor to run the HRA doesn't change it.

Step 2: Work out your count with the one-life rule

The chart says plan sponsors "are permitted to assume one covered life for each employee with an HRA." The regulation states the condition more exactly, and this is where you need to look at the rest of your benefits:

"One life per participant" tells you how many lives each person represents. You still need an average for the plan year, and that comes from one of the three self-insured methods. The two most likely for a small HRA are these:

• Actual count: add up the number of HRA participants on each day of the plan year, then divide by the days in the plan year.
• Snapshot: count participants on a date in each quarter of the plan year, then average those counts. The dates in later quarters must be within three days of the matching date in the first quarter.

Use the same method for the whole plan year. Our guide to average covered lives covers these in detail, including the Form 5500 method.

Step 3: Calculate the fee (a worked example)

The company and numbers are made up. Lakeside Dental Supply buys an insured group policy for its staff and offers an HRA that helps pay deductibles and copays. The HRA isn't an excepted benefit, and it has a plan year of July 1, 2025 through June 30, 2026. Lakeside has no other self-insured plan, so it uses one life per participant.

1. Average: 180 / 4 = 45 covered lives.
2. Rate: the plan year ends on or after October 1, 2025 and before October 1, 2026, so the rate is $3.84.
3. Fee: 45 x $3.84 = $172.80.
4. Due: July 31, 2027 is a Saturday, so Lakeside may file on Monday, August 2, 2027.

The insurer handles the fee on the group policy. Lakeside's return reports only the HRA. To try your own numbers, use the PCORI fee calculator.

If your HRA is on a calendar year, the 2025 plan year used $3.84 and was due July 31, 2026. A plan year ending on or after October 1, 2026, including calendar 2026, has no rate in our IRS sources yet. The IRS publishes it, so check the second-quarter 2027 Form 720 instructions. That plan year is also due Monday, August 2, 2027. If you've missed a filing, see our article on late PCORI filing.

Step 4: Find the line for your HRA on Form 720

An HRA is a self-insured arrangement, so it goes in the "Applicable self-insured health plans" section of Part II, under IRS No. 133. On the June 2026 revision:

Don't use lines 133(a) or 133(b). Those are for specified health insurance policies, even if your HRA sits alongside one. Enter the average lives in column (a), and the fee goes in column (c). Carry the total to the Tax column on the line for IRS No. 133. When you file, use the most current revision of the form, because the IRS updates it each year. Our article on line 133 explains the four sub-lines.

Step 5: File and pay

This is a short return when PCORI is the only item on it. Here's how to do it with EasyFile720, an IRS-authorized e-file provider:

1. Create a free account with no credit card, and enter your company's details and EIN.
2. Enter your average covered lives from Step 3. The rates for the return are built in, and the math is calculated for you.
3. Review anything the validations flag, then sign electronically and submit. You pay $39.95 when you file.
4. Look for the electronic acknowledgment from the IRS, which you'll get once it's accepted. Your return stays saved in your account.

Then pay the fee itself to the IRS by the due date. Deposits aren't required. The Form 720 instructions list IRS Direct Pay, EFTPS, electronic funds withdrawal when filing electronically, and check or money order with Form 720-V. If you use EFTPS, apply the payment to the second quarter.

Ready to finish? File your HRA's PCORI fee online with your count in hand. E-filing is available but not required for this fee.

FAQ

Sources: IRS chart of the PCORI fee on common types of coverage; IRS PCORI Questions and Answers; Instructions for Form 720 (Rev. June 2026); Form 720 (Rev. June 2026); 26 CFR 46.4376-1. General information, not tax advice. Confirm how the rules apply to you with a qualified advisor or the IRS.