Getting PCORI Numbers From Your TPA
To file the PCORI fee on a self-insured plan, you need one number: average covered lives for the plan year. Your third-party administrator (TPA), the company that processes claims and keeps enrollment, usually holds the data behind it. What you should ask for depends on which counting method you use. So decide the method first, then send a specific request instead of asking for "our PCORI number."
Why is this still your job if a TPA runs the plan?
IRS Q&A 7 says issuers and plan sponsors are responsible for reporting and paying the fee. For a plan maintained by a single employer, the regulation says the plan sponsor is the employer. A TPA isn't on that list, and nothing in the IRS sources we reviewed moves the duty to one.
The regulation does let a plan set up by several employers, outside its listed categories, name a sponsor in its plan document, but the named person must be one of those establishing or maintaining the plan. So the practical split is simple: your TPA can supply data, and you own the result. Our post on TPAs and PCORI filing covers who may prepare the return. This article is about getting the numbers right.
What should you ask for under each method?
| Your method | Ask the TPA for | How you use it |
|---|---|---|
| Actual count | Total covered lives for each day of the plan year, or a roster with each person's start and end dates | Add the daily totals and divide by the days in the plan year |
| Snapshot count | The actual number of covered lives on each date you chose | Add the counts and divide by the number of dates |
| Snapshot factor | On each date, participants with self-only coverage and participants with other coverage | Self-only, plus other coverage x 2.35, then average the dates |
| Form 5500 | Usually nothing from the TPA, unless it prepares the form: total participants at the start and end of the plan year, and the filing date | Self-only plans: add and divide by 2. Plans with other coverage: add only |
Whichever method you choose, the regulation requires you to use it for the whole plan year, though you can change next year. The covered lives guide compares the methods if you haven't picked one. If your TPA can only produce one type of report, that may settle the choice for you.
A request you can send
Fill in the brackets and adjust it to your method:
Each part of that request has a reason behind it:
- Plan year, not calendar year. The fee follows the plan year. A calendar-year report for a June 30 plan doesn't fit.
- COBRA and retirees. IRS Q&A 6 says these people and their beneficiaries count.
- Insured-only lives. If the plan has both insured and self-insured options, the regulation lets you leave out lives covered solely under the insured options. You can't do that unless the report separates them.
- HRA-only participants. When an HRA and a medical plan are treated as one plan, the one-life rule applies only to HRA participants who aren't on the medical plan.
What if the TPA only sends a monthly report?
TPAs may send a monthly enrollment summary, sometimes called "member months." The member months method itself is only for insurers, and it isn't on the list of three methods for plan sponsors. But the monthly counts may still help.
The snapshot method allows more than one date in each quarter, as long as each quarter has the same number of dates. So 12 monthly counts can work as three dates per quarter, if the dates line up. Each date in the later quarters must be within three days of the matching date in the first quarter, and all of them must fall in the plan year. Ask the TPA what day of the month each count was taken.
A made-up example: a plan year ended June 30, 2026. The TPA's counts, taken on the first of each month, add up to 1,464. Divide by 12 dates to get 122 average lives. At $3.84, the fee is 122 x $3.84 = $468.48. You can check your own figure with the PCORI fee calculator.
What should you check before you file?
- Does the count look like your plan? Compare it to your payroll enrollment. If the number of lives nearly equals the number of employees on a plan with family coverage, dependents may be missing.
- Do the snapshot dates pass the rule? Compare each date with the first-quarter date. The 30th and 31st are treated as the last day of a shorter month.
- Is the Form 5500 method actually open to you? The form must be filed no later than the fee's due date. In the regulation's example, a form filed under an extension after that date disqualifies the method.
- Does a short plan year apply? If the plan started or changed its year, use the actual length of the plan year.
- Does the math match the method? Redo the division yourself, and keep the TPA's report with your records.
Give the TPA enough lead time. Plan years that ended 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, which includes calendar 2026, so check the second-quarter 2027 instructions.
Your next step once the TPA replies
When you have your average covered lives, you have what the fee calculation needs. You can then file your PCORI fee online with EasyFile720. The filing is guided from business details through to submission. You enter your figures, the rates are built in, and the math is calculated for you. Validations catch common mistakes before you submit, you sign electronically, and you get an electronic acknowledgment from the IRS once the return is accepted.
Creating an account is free with no credit card, and a filing costs $39.95 when you submit. If you want to get the account ready while the TPA works on the report, start from the PCORI fee filing page and enter the number when it arrives.
FAQ
Can I use the member months report my TPA sent me?▼
Not as a member months calculation, because that method is only for insurers. If the report shows counts taken on matching dates each month, the same counts may fit the snapshot method, which allows more than one date per quarter when the number of dates per quarter is equal.
My TPA gave me a number but won't say how it was figured. Is that enough?▼
It is a weak position, because the sponsor must use one of the three methods for the whole plan year. Ask which method was used, the dates or period it covers, and whether dependents, COBRA, and retirees are included.
Should the TPA include dependents in the count?▼
Generally yes. IRS Q&A 5 says an employee and a dependent child are two lives on a self-insured plan. The exception is a sponsor whose only self-insured arrangement is an HRA or health FSA, which may count one life per participant.
We have an HRA and a medical plan through the same TPA. Do I need two counts?▼
If both have the same sponsor and plan year, they may be treated as one plan, so a person on both counts once. If the plan years differ, ask for separate figures.
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 (Q3, Q4, Q5, Q6, Q7, Q8); 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.
