Fully Insured? Do You File the PCORI Fee?
If every piece of your health coverage is a fully insured policy, you don't file the PCORI fee. Your insurance company does. IRS Q&A 7 places the duty on issuers of health insurance policies and on sponsors of self-insured plans, and the IRS chart says it plainly for major medical coverage: "the issuer if insured."
That means many employers searching for a "PCORI form" don't need one. If that is you, you don't need our service or anyone else's for this fee. The one check worth doing is whether something self-insured is sitting beside your policy.
What is the PCORI fee, briefly?
It is an annual federal fee that helps fund the Patient-Centered Outcomes Research Trust Fund, which pays for the Patient-Centered Outcomes Research Institute. It is charged per covered life and reported on Form 720, the federal excise tax return. The rate is $3.84 for policy years ending October 1, 2025 through September 30, 2026. For a fully insured policy, that is a matter between the insurer and the IRS.
Which of your benefits create a filing?
Fully insured employers often carry a few extra benefits. This table uses the IRS chart of coverage types:
| Benefit you offer | Subject to the fee? | Who is responsible |
|---|---|---|
| Insured major medical policy | Yes | The insurer |
| Insured retiree-only coverage | Yes | The insurer |
| COBRA under an insured policy | Yes | The insurer |
| HRA, including premium-only | Yes, unless an excepted benefit | You, the plan sponsor |
| Flexible spending arrangement | Yes, unless an excepted benefit | You, the plan sponsor |
| Stand-alone dental or vision | No | Nobody |
| Health Savings Arrangement | No | Nobody |
| On-site medical clinic | No | Nobody |
| Employee assistance or wellness program | No, if no significant medical care or treatment | Nobody |
The FSA row needs a second look. IRS Q&A 9 says most flexible spending arrangements provide only excepted benefits and so aren't subject to the fee, but it depends on whether the arrangement meets the requirements. An excepted benefit is a type of coverage the law carves out, such as plans limited to vision or dental benefits. The sources we reviewed don't spell out the test for an HRA, so ask your plan adviser whether yours qualifies.
More than one insured policy doesn't change the answer. The chart says each issuer is responsible for its own policy, so two carriers mean two insurers filing and still nothing for you. Having retirees or COBRA participants on the policy doesn't change it either.
The exception to watch: an HRA beside your policy
A Health Reimbursement Arrangement, or HRA, is an employer-funded account that reimburses medical costs. Reimbursing costs yourself is what makes it self-insured, even though the main policy isn't. The IRS chart gives this exact case: if an HRA can pay deductibles and copays under a health insurance policy, the HRA and the policy "would be subject to separate PCORI fees."
So you end up with two fees and two different filers:
- The insurer reports and pays on the policy, counting the lives it covers.
- You report and pay on the HRA, on your own Form 720.
Your side tends to be small. When an employer's only self-insured plan is an HRA or health FSA, the regulation lets it treat each participant as a single covered life, with no need to count spouses or dependents. A made-up employer with 30 HRA participants, and a plan year ending December 31, 2025, owes 30 x $3.84 = $115.20. You can test your own number with the PCORI fee calculator.
Are you sure the plan is fully insured?
Sometimes a plan that feels insured isn't. Three quick checks:
- Read the invoice and contract. A policy where the insurer takes premiums and bears the claims is insured. A contract that mentions "stop-loss" coverage points toward self-funding, so ask your broker to confirm.
- Ask about level funding. A steady monthly bill doesn't prove insurance. Our post on level-funded plans explains why these employers may have a filing.
- Look for mixed options. If your plan offers both insured and self-insured options, the self-insured part is yours. The regulation lets you leave out lives covered solely under the insured options, but you still file for the rest.
If you aren't sure after this, ask your broker in writing whether each benefit is insured or self-funded. It is a short email, and the answer tells you whether a filing is your job.
What to do based on your answer
Fully insured with no HRA or non-excepted FSA: stop here. You have no PCORI Form 720 to file, so there is nothing to submit and nothing to pay us for. This doesn't change any other excise tax you may owe, and our Form 720 filing check covers that broader question.
Fully insured plus an HRA or other self-insured arrangement: you owe once a year on the second-quarter Form 720, by July 31 of the year after the plan year ends. No other quarter is required if PCORI is your only excise tax, and deposits aren't required. Plan years ending in 2026 are due Monday, August 2, 2027, because July 31, 2027 is a Saturday. Plan years ending through September 30, 2026 take $3.84. The IRS publishes the rate for later plan years, so check the second-quarter 2027 instructions if your HRA runs on a calendar year.
For that second group, you can file your PCORI fee online with EasyFile720: enter your business details and HRA participant figure, sign electronically, and get an electronic acknowledgment from the IRS once the return is accepted. The account is free to create, and the filing costs $39.95 when you submit. If you want more detail first, read the PCORI fee filing guide.
FAQ
Do I need to tell the IRS that I am fully insured?▼
The IRS sources we reviewed don't describe any statement or form for this. The duty to report and pay falls on the issuer of the policy, so an employer with only insured coverage has no PCORI Form 720 to file.
Does an HSA create a PCORI filing for me?▼
No. The IRS chart lists Health Savings Arrangements as not subject to the fee, and the same goes for Archer MSAs.
We pay individual policy premiums through an HRA. Does that count?▼
The IRS chart lists an HRA, including a premium-only HRA, as subject to the fee with the plan sponsor responsible, unless the arrangement qualifies as an excepted benefit.
How much would a fee on an HRA be?▼
It is the number of covered lives times the rate for the plan year. If the HRA is your only self-insured plan, you may count one life per participant, so 30 participants on a plan year ending December 31, 2025 comes to $115.20.
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: IRS PCORI Questions and Answers (Q1, Q3, Q7, Q8, Q9); IRS chart of coverage types; Form 720 and Instructions for 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.
