HRA Plus Self-Insured Plan: One PCORI Count
One count, as long as two things match: the sponsor and the plan year. When a self-insured medical plan and a Health Reimbursement Arrangement (HRA) have the same plan sponsor and the same plan year, they may be treated as a single applicable self-insured health plan for the PCORI fee. An employee in both counts once. The chart goes a step further and says the HRA is then not subject to a separate fee.
If the plan years differ, the shortcut is gone. Each plan is measured on its own, and one person can appear in both counts. This article covers both cases with numbers. If your medical coverage is insured instead, this rule doesn't apply, and the answer is in our guide to PCORI on HRAs and FSAs.
The two tests for combining self-insured plans
The IRS coverage chart and 26 CFR 46.4376-1(b)(1)(iii) use the same two conditions:
- Same plan sponsor. For a single-employer plan, the sponsor is that employer. Other plans have other sponsors, such as a joint board of trustees for a multiemployer plan. Two companies each sponsoring their own arrangements don't pass this test.
- Same plan year. It is the plan year that must match, not the calendar date you pay or renew.
The rule also reaches beyond HRAs. The regulation's own example combines self-insured major medical with a separate self-insured prescription drug arrangement. Its other example has an employer with a calendar-year self-insured medical plan, a calendar-year HRA, and a self-insured dental and vision plan. The first two may be combined. The third isn't subject to the fee, so it stays out altogether.
Who counts when the plans are combined?
People usually ask if the one-life-per-employee HRA rule survives combination. It does, but only for some people. Under 26 CFR 46.4376-1(c)(2)(vi), the one-life rule applies only to participants in the HRA who are not in the other self-insured plan.
| Person | How they count in the combined plan |
|---|---|
| In the medical plan and the HRA | Under the medical plan's counting method, with covered dependents counted under that method. Not again for the HRA. |
| In the medical plan only | Under the medical plan's counting method. |
| In the HRA only | One life each. |
Here is an example. Harbor Tool Company is a made-up employer with both a self-insured medical plan and an HRA on a plan year ending June 30, 2026. The medical plan averages 480 lives, dependents included. The HRA has 200 participants: 170 are also in the medical plan, and 30 are not.
The combined count is 480 + 30 = 510 lives. At $3.84, the fee is $1,958.40. Adding all 200 HRA participants to the 480 would double-count 170 people and overstate the fee by $652.80. The PCORI fee calculator will run the same multiplication with your own count.
What changes when the plan years differ?
Three things change: the count, potentially the rate, and potentially the due date.
The count. The plans aren't combined, so you do not get the rule that a person in both counts once. Each plan gets its own average.
The rate. The rate depends on when each plan year ends. Suppose the same made-up employer has a medical plan year ending December 31, 2025 and an HRA plan year ending September 30, 2025. The two fall on opposite sides of the October 1, 2025 rate change, and both are reported by July 31, 2026:
| Plan | Plan year ends | Average lives | Rate | Fee | June 2026 line |
|---|---|---|---|---|---|
| Medical | Dec 31, 2025 | 480 | $3.84 | $1,843.20 | 133(d) |
| HRA | Sep 30, 2025 | 260 | $3.47 | $902.20 | 133(c) |
| Total in the Tax column for IRS No. 133 | $2,745.40 |
The due date. Each fee is due July 31 of the calendar year after that plan year ended. If the HRA year ended September 30, 2025 and the medical year ended January 31, 2026, the HRA fee was due July 31, 2026. The medical fee is due in 2027, on Monday, August 2, because July 31, 2027 is a Saturday. That means returns in two different years for one benefit program.
Names and numbers in this article are made up. For plan years ending on or after October 1, 2026, the rate is not in the IRS materials we reviewed. The IRS publishes it, so check the instructions for the second-quarter 2027 Form 720.
Two more details for a combined plan
A combined plan uses one counting method for the plan year, consistently from start to end. You can move to a different method the next year. Our covered lives guide compares them.
If the self-insured plan also offers a fully insured option, the sponsor may leave out lives covered solely under that option (26 CFR 46.4376-1(c)(2)(vii)). The insurer handles those. If your plan works this way, check that people you drop are not also in another self-insured part of the plan.
Reporting the result on your return
When the plans are combined, you report one average on one line. When they aren't and both fall due in the same year, the two fees are added together in the Tax column for IRS No. 133. The instructions say to combine the fees on that line.
EasyFile720 takes the figures you worked out. When you file your PCORI fee online, you enter average lives, the rates for the return are built in, and the math is calculated for you. Validations catch common mistakes before you submit. We don't decide whether your plans should be combined or count lives for you, so settle that with the table above first. An account is free with no credit card, you pay $39.95 when you file, and returns from past years stay saved so you can compare counts. For more on deadlines and lines, see the PCORI fee filing guide.
FAQ
Do we have to combine if both tests are met?▼
The regulation says the plans may be treated as one, so it reads as a permission. The chart adds that the HRA is not subject to a separate fee in that situation. Combining is the simpler route, and it avoids counting one person twice.
Can we change the HRA's plan year to match?▼
The PCORI sources say nothing on how to change a plan year. They do say a changed plan year can create a short plan year, and the fee applies to it, so plan the first filing with that in mind.
Does a prescription drug plan get combined the same way?▼
Yes, under the same conditions. The regulation gives a separate self-insured drug arrangement as an example of what can be combined with self-insured major medical when the sponsor and plan year match.
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 chart of PCORI coverage types; IRS PCORI Questions and Answers (Q5); 26 CFR 46.4376-1; Instructions for Form 720 (Rev. June 2026); Form 720 (Rev. June 2026). General information, not tax advice. Confirm how the rules apply to you with a qualified advisor or the IRS.
