Who Files PCORI for a Multiemployer Plan?
A self-insured multiemployer plan has one PCORI filer: its joint board of trustees. The federal regulation names the board as the plan sponsor, which means the board reports and pays the fee on its own Form 720. Contributing employers do not each file for that plan. A person the board authorizes signs the return.
That answer changes for other shared plans. A multiple employer welfare arrangement, a voluntary employees' beneficiary association, and a group plan with no named sponsor each follow a different line of the same rule. If you are working out who should file the PCORI fee for a shared plan, start by finding which line fits you.
Who is the plan sponsor for each kind of group plan?
The list below comes from 26 CFR 46.4376-1(b)(2). "Plan sponsor" is simply the party the fee rule holds liable for a self-insured plan.
| How the plan is set up | Plan sponsor who owes the fee |
|---|---|
| One employer | The employer |
| One employee organization | The employee organization |
| Multiemployer plan (Code section 414(f)) | The joint board of trustees |
| Multiple employer welfare arrangement (MEWA, ERISA section 3(40)) | The committee |
| Rural electric cooperative or rural cooperative association | The cooperative or association that establishes or maintains the plan |
| Voluntary employees' beneficiary association (VEBA) that actually establishes or maintains the plan | The trustee |
| Any other plan, with a sponsor named or designated in the plan document | That named or designated person |
| Any other plan, with nobody named or designated | Each employer, employee organization, board, cooperative, or association that establishes or maintains the plan, for its own people |
Two details in that table cause most of the confusion.
- The VEBA line has a condition. The trustee is the sponsor only when the VEBA itself establishes or maintains the plan. If the VEBA is merely a funding vehicle for a plan an employer maintains, the trustee line does not apply.
- "Multiemployer" is a defined term. The regulation points to Code section 414(f), and the IRS PCORI materials do not restate that definition. If you are unsure whether your fund meets it, ask plan counsel before you decide who files.
What does a contributing employer need to do?
For the multiemployer plan itself, nothing on Form 720. The board is the sponsor, and the board counts the lives. Your company may still be asked for headcount data, because the board needs accurate numbers from somewhere.
Watch for anything your company runs apart from the fund. An HRA you set up for your non-union staff is a separate arrangement with you as the sponsor. If it is an applicable self-insured health plan, you owe a fee on it, and that is true whatever the union fund does. Our guide to HRAs and FSAs under the PCORI fee covers how those are treated.
What if the plan document names no sponsor?
Some plans are set up by several employers and fit none of the specific lines above. The regulation then looks to the plan document.
The document can name a sponsor, or it can designate one for section 4376 purposes. A designation has conditions:
- It must be in writing, and the person designated must consent in writing.
- Both must happen no later than the date the return for that plan year is due. After that date, the designation for that plan year cannot be changed or revoked.
- The person must be one of those establishing or maintaining the plan, such as one of the participating employers.
With no identification or designation, every employer that establishes or maintains the plan is a sponsor for its own employees and their covered family members, and each one files a separate Form 720. The regulation's example uses a holding company whose three subsidiaries set up one group plan. With nothing in the document, all three file. If the document designates one subsidiary and it consents in time, that one files for everyone's covered lives.
For a group in that position, the choice is practical. One filer means one count and one return. Several filers mean several counts, several returns, and several signatures. If you want one filer, get the designation and the consent signed well before the deadline.
Who signs the return, and what goes at the top of it?
The Form 720 instructions say the form "must be signed by a person authorized by the entity to sign this return." For a joint board, that means a person the board has authorized. The IRS sources do not name a required title, and they do not require a particular number of trustees to sign. Keep a record of the authorization with your plan files.
You also need an EIN. The instructions state that you need one to file Form 720 and tell you to enter the correct EIN. They do not say anything specific about boards of trustees, so confirm with plan counsel which EIN and legal name belong to the sponsor before filing.
A fund office or administrator can do much of the work. If you want that person to be able to talk to the IRS about the return, the form has a Third Party Designee section. It does not move the liability. Our article on filing through a TPA explains the split.
A worked example for a joint board
The trust and the numbers here are made up. The Riverside Trades Health Trust is a self-insured multiemployer plan with a plan year of July 1, 2025 through June 30, 2026. Its joint board of trustees uses the actual count method, which means adding the lives covered on every day of the plan year and dividing by the number of days. It reaches an average of 3,400 covered lives.
- Find the rate. The plan year ends on or after October 1, 2025 and before October 1, 2026, so the rate is $3.84.
- Multiply. 3,400 x $3.84 = $13,056.00.
- Find the due date. The fee is due July 31 of the calendar year after the plan year ends. That is July 31, 2027, a Saturday, so under the weekend rule the board may file on Monday, August 2, 2027.
- Identify the return. It goes on the second-quarter Form 720. On the June 2026 revision, the $3.84 line for self-insured plans is 133(d). Use the most current revision when you file, since the IRS updates the form each year.
You can test your own average in the PCORI fee calculator. Boards often also ask whether the fee can come out of plan assets. That is a separate question from who files, and our article on paying the PCORI fee from plan assets covers it.
Filing for a board or fund online
Once the board has settled the sponsor question and has its count, the filing itself is short. With EasyFile720, you can file the PCORI fee online as an IRS-authorized e-file option. E-filing is available but not required for this fee.
- Create a free account. No credit card is needed to start, and you pay $39.95 when you file.
- Enter the sponsor's name and EIN as the business.
- Enter the average covered lives. The rates for the return are built in and the math is calculated for you.
- Review the validation results, sign electronically, and submit. You get an electronic acknowledgment from the IRS once the return is accepted.
A fund office or preparer handling several funds can file for multiple client businesses under one account, and past returns stay saved there.
FAQ
We contribute to a union health fund. Do we file Form 720 for it?▼
If the fund is a multiemployer plan, the regulation makes the joint board of trustees the plan sponsor, so the fee sits with the board. A self-insured arrangement your company runs on its own is a different plan, and your company is the sponsor of that one.
Does each trustee have to sign the return?▼
The Form 720 instructions ask for a signature from a person authorized by the entity to sign the return. They do not call for every trustee to sign, and they do not name a particular officer.
Can a third-party administrator take over the liability?▼
The IRS sources place the fee on the plan sponsor and do not describe any way to shift it to an administrator. An administrator can help with the work, but the sponsor stays responsible.
What if the multiemployer coverage is fully insured?▼
The fee on an insurance policy falls on the issuer. The board owes the sponsor fee only if some part of the coverage is provided other than through an insurance policy.
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 Questions and Answers. General information, not tax advice. Confirm how the rules apply to you with a qualified advisor or the IRS.
