Self-Insured Employer PCORI Filing Guide
If your company self-insures its health plan, the PCORI fee is yours to file. No insurer does it for you. The job has five parts: confirm you owe, count your average covered lives, find the rate and line, file the second-quarter Form 720, and pay. The rest of this guide takes those in order, so you can finish by working through it with your plan records open.
Want to see the end point first? This is the return you will file online for the PCORI fee: one form a year, one number for lives, one fee.
Step 1: Confirm your self-insured plan owes the fee
The regulation calls your plan an "applicable self-insured health plan" if it provides accident and health coverage, any portion of it is provided other than through an insurance policy, and it is maintained by one or more employers for employees or former employees. Use this table to sort what you have.
| What you have | Do you file for it? |
|---|---|
| Medical plan where you pay the claims | Yes. The employer is the plan sponsor. |
| Self-insured retiree-only coverage or COBRA | Yes. |
| HRA, including a premium-only HRA | Yes, unless it is an excepted benefit. |
| Health FSA | Yes, unless it is an excepted benefit. The IRS says most FSAs are not subject to the fee. |
| Stop-loss policy on your plan | No separate fee. You still owe the fee on the plan itself. |
| Stand-alone dental or vision | No. |
| Fully insured group policy | No. The issuer is responsible. |
A level-funded arrangement needs a careful look before you put it in the last row. Our article on level-funded plans explains why. If your plan is shared among several employers, the sponsor may be someone else, so check the plan document first.
Step 2: Choose a counting method and find your average
The fee is based on the average number of lives covered during the plan year. Employees count, and so do covered spouses, dependents, retirees, and COBRA participants. A self-insured sponsor must use one of three methods:
| Method | How it works | A good fit when |
|---|---|---|
| Actual count | Add the lives covered on each day of the plan year, then divide by the number of days | Your system can report daily enrollment |
| Snapshot | Count lives on at least one date in each quarter of the plan year, then average. You can count people, or use self-only participants plus other participants x 2.35. | You can pull enrollment on set dates |
| Form 5500 | Use participant totals from the Form 5500 or 5500-SF filed for the plan. It must be filed by the fee's due date. | You file that form on time and want to reuse its numbers |
Three rules apply to any of them:
- Stick with one method for the whole plan year.
- If your plan also has fully insured options, you may leave out lives covered solely under those options.
- If you run several self-insured arrangements with the same plan year, such as medical and drug coverage, you may treat them as one plan so that one person counts once.
Our guide to counting average covered lives shows each method with numbers. EasyFile720 doesn't choose the method or count lives for you, so finish this step before you start the return.
Step 3: Find your rate, line, and due date for the PCORI filing
All of this depends on the last day of your plan year. Its start date doesn't matter. The lines below are from the June 2026 revision of Form 720, and self-insured plans use lines 133(c) and 133(d). Lines 133(a) and 133(b) are for insurers.
| Plan year ends | Rate | Line | Due |
|---|---|---|---|
| Oct 1, 2024 to Sep 30, 2025 | $3.47 | 133(c) | July 31 of the next calendar year |
| Oct 1 to Dec 31, 2025 | $3.84 | 133(d) | July 31, 2026 |
| Jan 1 to Sep 30, 2026 | $3.84 | 133(d) on the June 2026 form | Monday, August 2, 2027 |
| Oct 1 to Dec 31, 2026 | Not yet in our IRS sources | Check the 2027 form | Monday, August 2, 2027 |
The date moves to August 2 because July 31, 2027 is a Saturday, and the instructions let you file on the next business day. For anything due in 2027, use the most current revision of the form, because the IRS updates it each year. The rate for plan years ending on or after October 1, 2026 will be in the second-quarter 2027 Form 720 instructions.
A worked example
The company and numbers are made up. Harbor Tool Co. self-insures its medical plan, with a plan year of July 1, 2025 through June 30, 2026. It uses the snapshot method and counts actual covered lives on one date per quarter of the plan year: 240, 250, 260, and 250.
- Average: (240 + 250 + 260 + 250) / 4 = 250 lives.
- Rate: the plan year ends June 30, 2026, so $3.84.
- Fee: 250 x $3.84 = $960.00.
- Due: Monday, August 2, 2027.
You can check your own figure with the PCORI fee calculator.
Step 4: File the second-quarter Form 720
PCORI is reported in Part II of the form. You enter the average lives in column (a), the rate is in column (b), and the fee goes in column (c). The total goes in the Tax column on the line for IRS No. 133. It doesn't matter what your plan year is. The IRS uses the second-quarter return for all PCORI filers.
If PCORI is your only Form 720 item, you file this one return a year and skip the other three quarters. If you also report other excise taxes, it goes on your regular second-quarter return, and you make no IRS No. 133 entry on the other quarters.
You'll need your EIN and a signature from someone your company has authorized to sign. E-filing is available but not required.
To do it online with EasyFile720, an IRS-authorized e-file provider:
- Create a free account. No credit card is needed to start.
- Enter your business details, following the guided steps.
- Enter your average covered lives. The rates for the return are built in, and the math is calculated for you.
- Fix anything the validations flag, then sign electronically and submit. The filing costs $39.95, and you pay when you file.
- Watch for the electronic acknowledgment from the IRS, which you'll get once the return is accepted.
When your count is ready, you can start your PCORI filing. There is more about sponsors on our self-insured health plan page.
Step 5: Pay the fee to the IRS
Payment is due when the return is due. Filing the return and paying the IRS are two separate things to check off, so confirm both are done. The instructions allow these ways to pay a balance:
- IRS Direct Pay, a transfer from a checking or savings account at no cost.
- EFTPS, which requires you to be enrolled. Apply the payment to the second quarter.
- Electronic funds withdrawal, if you are filing electronically.
- Check or money order, with Form 720-V, the payment voucher.
Don't file Form 720-V if you pay by Direct Pay, EFTPS, or direct debit. If the deadline has already passed for a plan year, read about late PCORI filing and penalties.
FAQ
Our TPA pays the claims. Does the TPA owe the fee?▼
The IRS places the fee on the plan sponsor of a self-insured plan, and for a single-employer plan that is the employer. An administrator can help with the work, but the IRS sources do not move the liability to it.
Can we pay the fee in installments through the year?▼
Deposits are not required for this fee. It is reported once a year, and payment is due when the Form 720 is due.
Can we change counting methods next year?▼
Yes. You must use one method consistently for the whole plan year, but the regulation lets you use a different method from one plan year to the next.
How long should we keep the records behind our count?▼
The Form 720 instructions say to keep records to support your return, and to keep records for claims and exemptions at least 4 years from the latest of the tax due date, the payment date, or the claim date. Keep your count with the return.
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); IRS PCORI Questions and Answers; IRS chart of the PCORI fee on common types of coverage; 26 CFR 46.4376-1. General information, not tax advice. Confirm how the rules apply to you with a qualified advisor or the IRS.
