PCORI Filing: EIN and Who Signs Form 720
The EIN on a PCORI return belongs to whoever owes the fee. For a self-insured plan, that is the plan sponsor, which is not necessarily the company that runs your claims or the one preparing the return. For an insured policy, it is the issuer. On signatures, the Form 720 instructions set one short rule: the return "must be signed by a person authorized by the entity to sign this return."
Those two questions cause real trouble in group structures and outsourced benefit setups, so this guide covers each in turn. For the fee itself, see the PCORI fee overview.
Which EIN goes on the PCORI form 720?
Regulation 26 CFR 46.4376-1 defines the plan sponsor by plan type. Find your plan below. The sponsor's employer identification number (EIN) is the one for the return.
| Self-insured plan set up by | Plan sponsor |
|---|---|
| A single employer | The employer |
| An employee organization | The employee organization |
| A multiemployer plan | The joint board of trustees |
| A multiple employer welfare arrangement | The committee |
| A rural electric cooperative or rural cooperative association | The cooperative or association |
| A voluntary employees' beneficiary association | The trustee |
| Anything else, with a sponsor named in the plan document | The person identified or designated in the document |
| Anything else, with no sponsor named | Each employer, organization, or board that set up the plan, filing separately |
The same logic applies to an HRA that sits beside insured coverage. The IRS chart says the HRA's fee falls on the plan sponsor, while the issuer handles the policy.
Several related companies share one plan: whose EIN?
This depends on what the plan document says. The regulation gives an example of a holding company with three subsidiaries that set up one self-insured group health plan, and it plays out two ways:
- No sponsor named in the document. Each subsidiary files its own Form 720 under its own EIN, reporting only the lives tied to its own employees.
- The document designates one subsidiary. That subsidiary files one Form 720 under its EIN, covering the lives of all three.
A designation has limits. It must be in writing, the designated person must consent in writing no later than the return's due date, and it can't be changed or revoked for that plan year after that date. The designated person must also be one of those establishing or maintaining the plan. In the regulation's example, the holding company has no employees and did not set up the plan, so it isn't the sponsor just because it owns the group.
Disregarded entities and QSubs use their own EIN
A disregarded entity is a single-owner business that income tax rules generally ignore. For excise tax, the rule flips. The instructions say qualified subchapter S subsidiaries (QSubs) and eligible single-owner disregarded entities are treated as separate entities. They must pay and report excise taxes under their own EINs, and "these actions can't take place under the owner's taxpayer identification number." The only excise taxes the instructions exclude are IRS Nos. 31, 51, and 117. The PCORI fee, IRS No. 133, isn't among them.
So if a disregarded LLC is the employer sponsoring the plan, use the LLC's EIN, not its parent's. The instructions point anyone unsure whether they already have an EIN to the IRS Business and Specialty Tax Line at 800-829-4933.
How an EIN mistake shows up on an e-filed return
The IRS publishes the checks it runs on e-filed returns. Three involve the EIN directly:
- Name mismatch (R0000-922-01). The EIN and name control must match the IRS e-file database. A name control is the short form of the name the IRS keeps with an EIN, so enter the legal name the IRS has, not a trade name or the name of the plan.
- Duplicate (R0000-914-01 and R0000-915-01). A return is rejected if that EIN already has an accepted electronic or paper return for the same return type and quarter. If one sponsor has two plans whose years end in the same calendar year, both go on one return, using separate 133 lines where the rates differ. A plan year ending in a different calendar year goes on that year's return.
- Placeholder (R0000-021). The EIN can't be all nines.
If you don't have an EIN yet, you can apply online at IRS.gov/EIN, or fax or mail Form SS-4. The instruction that a one-time filer may not need an EIN points to gas guzzler tax, so don't rely on it for PCORI.
Who signs Form 720 for PCORI?
The instructions don't list approved job titles. They require a person authorized by the entity, and the form asks for a signature, printed name, date, title, and telephone number. The signature is made under penalties of perjury, so the signer is declaring the return has been examined and is true, correct, and complete. Whoever signs should have real sight of the covered-lives figure.
Other people can touch the return, but in different roles:
| Role | What the instructions say | Replaces the entity's signer? |
|---|---|---|
| Paid preparer | Must sign and complete the Paid Preparer section if paid to prepare and not an employee. Uses a PTIN, and the firm EIN cannot stand in for it. Must give you a copy. | No, the form has a separate section |
| Third party designee | May discuss the return with the IRS. Authorization expires 1 year from the due date. Cannot bind you or otherwise represent you. | No |
| Your employee who prepared it | Does not use the Paid Preparer section | Only if authorized by the entity to sign |
For wider authority than a designee has, the instructions point to Pub. 947, Practice Before the IRS and Power of Attorney. If an outside administrator handles your filing, our guide on TPAs and PCORI filing and our guide to the paid preparer section go further.
Getting these details right when you file online
When you file your PCORI form online with EasyFile720, the guided filing starts with your business details. Use the sponsor's legal name and EIN, worked out from the table above. EasyFile720 does not decide who your plan sponsor is. That comes from your plan document. Before you submit, validations catch common mistakes, and the authorized person then signs electronically. Preparers can file for multiple client businesses under one account. You can check the amount you will report with the PCORI fee calculator. Once you know the EIN and the signer, your next step is to start filing Form 720 online. The account is free to create, with no credit card needed to start, and you pay $39.95 when you file.
FAQ
Can our third-party administrator file under its own EIN?▼
The EIN on the return identifies the party that owes the fee, and the regulations define that party as the plan sponsor. They do not list an administrator as a plan sponsor simply for running the plan.
Can I use a Social Security number if the business has no EIN?▼
Plan on an EIN. The instructions tie the exception for not needing an EIN to one-time gas guzzler filers, not to the PCORI fee, and you can apply for an EIN online at IRS.gov/EIN.
Is a third party designee the same as a signer?▼
No. A designee can discuss the return with the IRS for a limited time. The instructions say this does not authorize that person to bind you to anything or otherwise represent you before the IRS.
Our benefits manager prepared the return. Does she sign the paid preparer section?▼
Not if she is your employee. That section is for a preparer who was paid to prepare the form and is not an employee of the filing entity.
File your PCORI fee online
Create a free account with no credit card and build your return. You pay $39.95 only when you file. EasyFile720 is an IRS-authorized e-file provider, and you get an acknowledgment when the IRS accepts your return.
Sources: Instructions for Form 720 (Rev. June 2026); Form 720 (Rev. June 2026); 26 CFR 46.4376-1; IRS PCORI coverage chart; 720 Business Rules Publication 2026Q4v1.0. General information, not tax advice. Confirm how the rules apply to you with a qualified advisor or the IRS.
