Multiple Self-Insured Plans and PCORI
Multiple self-insured plans may be treated as one for the PCORI fee, but only if two things match: the plan sponsor and the plan year. When they match, a person covered by both counts as one life. When either one differs, each plan owes its own fee. There is no matching rule for insurance policies.
This matters most when you run medical, prescription drug, and HRA benefits as separate arrangements. Done correctly, it stops you paying twice for the same person. Getting it wrong means a return with the wrong average, so settle it before you file the PCORI fee.
When can you combine plans for the PCORI fee?
The rule is at 26 CFR 46.4376-1(b)(1)(iii), and the IRS chart repeats it. Generally, separate fees apply for lives covered by each policy or plan. The exception needs both of these:
- The same plan sponsor. Usually that is one employer, but see who is liable when a TPA is involved if you are unsure who your sponsor is.
- The same plan year. A calendar-year plan and a June 30 plan don't qualify, even with the same employer and the same people.
Here is how common arrangements come out:
| Arrangements | Sponsor | Plan year | Result |
|---|---|---|---|
| Self-insured medical + self-insured drug plan | Same | Same | May be treated as one plan |
| Self-insured medical + HRA | Same | Same | May be treated as one plan |
| Self-insured medical + HRA | Same | Different | Separate fees |
| Two plans run by two employers | Different | Same | Separate fees |
| Insured policy + HRA | Issuer and employer | Any | Separate fees |
| Two insured policies | Each issuer | Any | Separate fees. No combining rule. |
Why don't insurance policies combine?
The IRS chart is blunt: "There is no similar rule for lives covered by more than one insurance policy subject to the PCORI fee." An employee covered under two policies is counted under each one, and each issuer is responsible for its own fee.
If your only coverage is insured, this isn't your filing problem, since issuers handle the fee on their policies. It affects an employer only when a self-insured arrangement sits next to the policy. An HRA that pays deductibles and copays under an insured policy owes its own fee, because the HRA and the policy can't be merged. The same HRA paying deductibles under a self-insured plan, with the same sponsor and plan year, does not owe a separate fee. Our guide to HRAs and FSAs has more on these arrangements.
How do you count covered lives when plans are combined?
Once combined, you count people rather than enrollments. The regulation's example is a major medical plan and a drug plan: someone in both counts as one covered life.
An HRA has one wrinkle. The usual HRA shortcut allows one life per participant, leaving out spouses and dependents. When you combine an HRA with a self-insured medical plan:
- Participants in both are counted the way the medical plan is counted, including their covered dependents.
- Participants only in the HRA may still use the shortcut and count as one life each.
Pick one counting method and use it for the whole plan year. The methods themselves are explained in our guide to average covered lives.
If a self-insured plan also offers a fully insured option, the regulation lets you leave out lives covered solely under the insured option when you count.
Example: the same employer, combined and not combined
The employer and numbers are made up. Northline Foods self-insures its medical plan and also offers an HRA. Under the medical plan's counting method, the plan averages 200 lives, including dependents. Some HRA participants are on the medical plan. An average of 30 are not.
Version 1: both plans run on the calendar year 2025. Same sponsor and same plan year, so they may be combined.
- Medical plan lives, including HRA participants already on that plan: 200.
- HRA-only participants at one life each: 30.
- Combined average: 230 lives.
- 230 x $3.84 = $883.20 on line 133(d) of the June 2026 form.
Version 2: the medical plan stays on the calendar year 2025, but the HRA year ends June 30, 2025. The plan years differ, so each plan pays its own fee. Assume the HRA averages 90 lives.
| Plan | Average lives | Rate | Line (June 2026 form) | Fee |
|---|---|---|---|---|
| Medical, year ended Dec 31, 2025 | 200 | $3.84 | 133(d) | $768.00 |
| HRA, year ended June 30, 2025 | 90 | $3.47 | 133(c) | $312.30 |
| Total on the line for IRS No. 133 | $1,080.30 |
Both plan years ended in 2025, so both were due on the same return, July 31, 2026. Version 2 costs more here partly because the people on both plans are counted in each.
Different plan years also can mean different due dates. A medical plan year ending December 31, 2026 and an HRA year ending June 30, 2026 both fall due in 2027, but a medical plan ending December 31, 2025 and an HRA ending June 30, 2026 fall due a year apart. The PCORI fee calculator can check each piece.
Filing once you've decided
Write down, for each arrangement, its sponsor and plan year, and whether it's being combined with another. Keep that note with your count, so that next year's filer can see why the average was built the way it was.
To file your PCORI fee online with EasyFile720, create a free account with no credit card. You pay $39.95 when you file. Once you've settled your averages, the guided steps take your figures, apply the rates for the return, and do the math. Validations catch common mistakes before you submit. EasyFile720 won't decide for you whether to combine plans or how to count, so have that settled first. You'll get an electronic acknowledgment from the IRS once it's accepted, and if several employers are involved, a preparer can file for each under one account.
FAQ
Do we have to combine our plans if they qualify?▼
No. The regulation says the arrangements may be treated as a single plan, so it is permitted rather than required. Combining generally avoids counting the same person more than once.
Our sister company runs its own plan with the same plan year. Can we combine?▼
The rule requires the same plan sponsor. Two employers that each sponsor their own plan do not meet it, and our IRS sources do not give a combining rule based on common ownership.
Does a dental plan need to be combined in?▼
No. Stand-alone dental or vision coverage is not subject to the fee, so there is nothing to combine. The regulation's own example leaves a self-insured dental and vision plan out.
Do combined plans go on one line of Form 720?▼
Combined plans are treated as one applicable self-insured health plan, so you report their single average at the rate for that plan year. Separate plans with different rates use their own lines and the total goes in the Tax column.
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 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.
