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How to Calculate, File, and Pay the PCORI Fee

Learn how to calculate your PCORI fee, complete IRS Form 720, and submit payment on time with step-by-step guidance for HRA plan sponsors.

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Written by Mel Vazquez-Martinez

Just looking for your PCORI document? You don't need to read this whole article. Log in to the HRA Hub Admin Portal → open the Documents tab → set the year filter to the correct plan year (it often defaults to a prior year). If the document still doesn't appear, contact Customer Experience and they'll send it directly.


If you’re required to pay the PCORI fee, this guide walks you through how to calculate your fee, complete IRS Form 720, and submit payment.
PY 2025 PCORI Fee Instructions

Can't find your PCORI document in the Admin Portal? This is the most common reason customers contact support about PCORI. Log in to the HRA Hub Admin Portal → Documents tab → check that the year filter is set to the correct plan year (it often defaults to a prior year). If the document still doesn't appear after checking the filter, contact Customer Experience — it may not have been generated yet or may need to be sent to you directly.

Multiple employer entities? Each entity with its own HRA plan requires a separate Form 720 filing and a separate covered-lives count. If you manage multiple entities, log in to each employer's Admin Portal separately to retrieve each entity's PCORI document. Contact Customer Experience if you are unsure which accounts have separate documents.

Getting your covered-lives data from Take Command

Take Command provides a PCORI document for each employer with an active or recently active HRA. This document includes your estimated covered-lives count based on your enrollment data, along with tips for completing Form 720. You do not need to perform a manual employee count if you use this document as your starting point.

  • Where to find it: log in to the HRA Hub Admin Portal and open the Documents tab. If the document does not appear, check that the year filter is set to the current plan year — documents are organized by plan year and may not display if the filter defaults to a prior year.

  • When to expect it: the document is typically available in June, ahead of the July 31 deadline.

  • If you don't see it by mid-June: contact Customer Experience — it may not have been generated yet or may need to be sent to you directly.

  • June email notification: Take Command also sends an email in June with your group-specific PCORI estimate and filing instructions, including your estimated covered-lives count. If you did not receive this email, check your spam folder — the PCORI document is also available directly in the Admin Portal Documents tab regardless of whether the email arrived.

  • For manual verification of your covered-employee count: your Enrollment Report is available in the HRA Hub Admin Portal under the Reports tab — filter by plan year to view enrolled employees by period. Contact Customer Experience if you cannot locate the Enrollment Report.

  • If your account was canceled or you no longer have portal access: contact Customer Experience and they can email your PCORI documents directly. You are still required to file Form 720 and pay the PCORI fee by July 31 regardless of your account status with Take Command.

The covered-lives count Take Command provides is an estimate based on your enrollment data. You are responsible for verifying its accuracy and completing the Form 720 filing yourself. Take Command does not file or pay the PCORI fee on your behalf.

What counts as a covered life — and who should I include in my count?

For HRAs, covered lives are the employees (and any enrolled dependents, if your plan covers them) who were enrolled in eligible individual health insurance during the plan year. Do not include:

  • Employees who enrolled in the HRA but did not maintain eligible health coverage

  • Employees whose coverage was terminated during the year for the months they were not covered

  • COBRA participants who are not enrolled in your HRA

The covered-lives count in Take Command's PCORI document is based on your enrollment data. To verify it manually, download the Enrollment Report from the Reports tab in the HRA Hub Admin Portal — filter by the plan year and count enrolled employees per quarter. Contact Customer Experience if your Enrollment Report is missing or shows unexpected numbers.




Step 1: Calculate your average covered employees

The PCORI fee is calculated as:

Average number of covered employees × applicable fee

Methods for calculating average covered lives

The IRS allows several methods, but the most common for HRAs is:

Snapshot method (recommended)

  1. Choose a consistent date each quarter (e.g., first day of each quarter)

  2. Count enrolled employees on that date

  3. Average those counts


Alternative: Actual count method

You may also:

  • Total covered employees for each day of the plan year

  • Divide by the number of days in the plan year

💡 This method is more precise but more time intensive.

For edge cases — such as mid-year hires, terminations, or plans with zero covered employees — refer to the IRS Instructions for Form 720 or consult a licensed tax professional for guidance specific to your situation.


Step 2: Determine your applicable fee:

Plan Year End Dates

Fee

Oct 1, 2025 – Sep 30, 2026

$3.84

Oct 1, 2024 – Sep 30, 2025

$3.61

Use your HRA plan year end date (not the calendar year) to determine the applicable rate. Form 720 does not have a plan year field — the plan year end date determines only which rate applies. You will always report PCORI on the Q2 filing due July 31, regardless of when your plan year ends. Your plan year end date is shown on Take Command's PCORI document in the Documents tab of the HRA Hub Admin Portal.

How do I find my HRA plan year end date?

Your plan year end date appears on the PCORI Fee Instructions document in the Admin Portal Documents tab. If you cannot locate that document, it is also shown in your HRA setup details in the Admin Portal.

Common plan year end dates and their applicable rates:

  • Calendar year plans (Jan 1 – Dec 31): plan year ends Dec 31

  • Non-calendar year plans: your plan year end date is shown in your PCORI document

If you are unsure which rate applies, contact Customer Experience with your plan year start date and they can confirm the correct rate and plan year end date for your account.



Step 3: Complete Form 720

You will report the PCORI fee on:

  • Form 720 (Quarterly Federal Excise Tax Return)

If the IRS link shows "DRAFT — Do Not File", the final Form 720 has not yet been published for this filing year. This can occur in the weeks before the July 31 deadline. Revisit IRS.gov closer to the deadline and wait for the final version before submitting. If the IRS link returns a 404 or page not found error instead, the URL may have changed — search for 'Form 720 Quarterly Federal Excise Tax Return' directly at IRS.gov to find the current version, or use the IRS Instructions PDF link in the Additional Resources section below.

Key sections to complete:

  • Part II, IRS No. 133 (PCORI fee line)

  • Enter:

    • Average covered lives

    • Applicable rate

    • Total fee


Step 4: File by the deadline

  • Due date: July 31 each year

Important:

  • PCORI is filed annually, even though Form 720 is quarterly

  • It is included only in the Q2 filing


Step 5: Submit your payment

Option 1: Pay by mail

Send:

  • Completed Form 720

  • Form 720-V

  • Check or money order

Internal Revenue Service
Department of the Treasury
Ogden, UT 84201-0009


Option 2: Pay electronically (EFTPS)

⚠️ You must still mail Form 720, even if you pay electronically.

Note: Even if you pay electronically via EFTPS, you must still mail a completed paper Form 720 to the IRS. Electronic payment does not substitute for the paper filing. The EFTPS payment deadline (July 29, 8:00 PM ET) is earlier than the July 31 mailing deadline — submit your EFTPS payment first, then mail Form 720 before July 31.


Filing tips and best practices

  • ✅ Double-check your employee counts for accuracy

  • ✅ Use a consistent calculation method year over year

  • ✅ Keep documentation in case of an IRS audit

  • ✅ Set a reminder each June/July to prepare filing


What if I file Form 720 quarterly already?

If you file Form 720 for other excise taxes:

  • Only include the PCORI fee on your second-quarter return (Q2)


Common filing questions

Which period do I enter on Form 720?

Enter Q2 (April 1 – June 30) as the filing period on Form 720, regardless of your HRA plan year end date. PCORI is always filed on the Q2 return due July 31.


I'm a new employer and my HRA started mid-year. Do I still need to file?

Yes, if your HRA was active for any months during the plan year and at least one employee was enrolled, you owe PCORI for those months. Use only the months the HRA was active when calculating your average covered lives.


My PCORI document shows zero enrolled employees. Is that correct?

If your document shows zero or an unexpectedly low count, your portal enrollment data may be incomplete. Do not file using a zero count without confirming with Customer Experience first — they can review your account data and confirm or correct the covered-lives figure.



The PCORI document shows a plan year I didn't expect — which year does it cover?

The document labeled "PY 2025" covers your plan year that ended in 2025 and is used for the Form 720 filing due July 31, 2026. Take Command releases this document in June of the filing year (June 2026 for PY 2025). When searching in the Admin Portal Documents tab, filter on the plan year the document covers — filter on 2025 to find the document for the July 31, 2026 filing. The document for the plan year currently in progress will not be available until the following June.


My account was cancelled — how do I get my PCORI document without portal access?

If your Take Command account has been cancelled or you no longer have portal access, contact Customer Experience and request that your PCORI document be sent by email. Include your company name, the plan year you need the document for, and your contact email address. You are still required to file Form 720 and pay the PCORI fee by July 31 even if your account is no longer active — do not delay filing while waiting for the document.


I manage multiple employer entities — do I need a separate Form 720 for each?

Yes. Each employer entity with its own HRA plan requires a separate Form 720 filing and a separate covered-lives count. Log in to each entity's Admin Portal separately to retrieve each entity's PCORI document. If you are unsure which of your accounts have separate documents or separate filing obligations, contact Customer Experience with your company names and they will confirm.

How do I know the IRS received my Form 720?

If you filed by mail, the IRS does not send automatic confirmation. For confirmation, file via a certified mail service (USPS Certified Mail or similar) and retain the tracking receipt. If you paid via EFTPS, your EFTPS account will show a payment confirmation number — keep this as your record. Take Command cannot confirm receipt of your IRS filing.

Additional resources


Disclaimer

This article is for general informational purposes only and should not be considered tax advice. Please consult a licensed tax professional for guidance specific to your situation.


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