This article is for employers offering a QSEHRA or ICHRA through Take Command who need to understand their PCORI fee filing and payment responsibilities.
Employers sponsoring a QSEHRA or ICHRA are generally responsible for paying the Patient-Centered Outcomes Research Institute (PCORI) fee and filing IRS Form 720 each year. PY 2025 PCORI Fee Instructions
Looking for your PCORI estimate? Each June, Take Command sends your covered-lives estimate and Form 720 instructions to your registered account email. If you did not receive it, check your Spam folder first, then log in to HRA Hub Admin Portal and check the Documents tab — use the plan year filter if documents are not visible. If still missing, contact Customer Experience to request a resend.
IRS Form 720 unavailable? If the IRS Form 720 link is broken or the form is not yet available on IRS.gov, this is an external IRS publishing delay — not a Take Command issue. The form is typically published in the spring. Check IRS.gov directly, or search 'Form 720' at irs.gov. Take Command cannot expedite IRS form availability.
What is the PCORI fee?
The Patient-Centered Outcomes Research Institute (PCORI) fee is a federal fee that helps fund medical research and healthcare outcomes studies.
The fee applies to sponsors of certain self-insured health plans, including most HRAs.
Employers are responsible for:
Calculating the fee
Filing IRS Form 720
Paying the fee directly to the IRS
Take Command does not file or pay the PCORI fee on behalf of employers.
Who is responsible for paying the fee?
The employer sponsoring the HRA is responsible.
Take Command does not:
Calculate your PCORI fee
File Form 720
Submit payment to the IRS
Provide tax filing services
Employers should work with their tax advisor, CPA, payroll provider, or benefits consultant if they need assistance.
Who does the PCORI fee apply to?
The PCORI fee applies to:
Employers that sponsor self-insured health plans
Insurance carriers offering fully insured plans
💡 If you have a fully insured group health plan, your carrier pays the fee—you do not need to take action.
How is the PCORI fee calculated?
The fee is calculated using:
The applicable IRS fee amount for the plan year
The average number of covered lives under the HRA
The IRS updates the fee amount periodically.
For most HRAs:
The employer counts covered employees
Dependents generally do not need to be counted separately under HRA counting rules
Employers should review current IRS guidance for the applicable filing year.
Does the PCORI fee apply to HRAs?
Yes. HRAs are considered self-insured health plans, so the employer is responsible for the PCORI fee.
This includes:
QSEHRA (Qualified Small Employer HRA)
ICHRA (Individual Coverage HRA)
Other employer-funded HRAs
What counts as a “covered life” for HRAs?
Unlike traditional medical plans, HRAs follow a simplified rule:
✅ Count:
Employees enrolled in the HRA
❌ Do NOT count:
Spouses
Dependents
Employees who waived participation
Former employees with no active coverage during the plan year
How much is the PCORI fee?
The fee is based on your average number of covered employees during the plan year.
Plan Year End Dates | Rate per Covered Life | Filing Due Date |
Oct 1, 2025 – Sep 30, 2026 | $3.84 | July 31, 2026 |
Oct 1, 2024 – Sep 30, 2025 | $3.61 | July 31, 2025 |
💡 The rate is adjusted annually for inflation.
PCORI is always reported on the second-quarter Form 720 (Q2), due July 31 each year — regardless of when your plan year ends. Use your plan year end date only to look up which per-covered-life rate applies in the table above.
Form 720 covers many types of federal excise taxes — not just PCORI. When filing the PCORI fee, you will report it specifically on Part II, IRS No. 133. If you open Form 720 and see sections about fuel taxes, transportation, or other excise items, you have the right form — scroll to Part II to find the PCORI fee line. For a step-by-step walkthrough of completing Form 720 for PCORI, see ‘How to Calculate, File, and Pay the PCORI Fee’ in the Help Center.
Do I need to file?
You must file and pay if:
You had at least one enrolled employee during the plan year, and
Your average covered lives is greater than 0
You do NOT need to file if:
No employees participated in your HRA at any point during the plan year
Common scenarios
New HRA started mid-year
You still need to:
Calculate your average based on the months the plan was active
File and pay if the average is greater than 0
Employees enroll and terminate throughout the year
That’s expected. Your average will:
Include fluctuations
Be calculated using a consistent method (like snapshot)
You offered both ICHRA and a group plan
ICHRA → You must pay PCORI
Fully insured group plan → Carrier pays PCORI
HRA was cancelled or terminated during the year
If your Take Command plan or HRA was cancelled mid-year:
You are still responsible for PCORI for the months the HRA was active.
Calculate your average covered lives using only the months the plan was in effect.
File and pay if the resulting average is greater than 0.
What happens if I do not file?
Failure to file or pay required fees may result in:
IRS notices
Penalties
Interest charges
Employers should ensure filings are completed by the applicable deadline.
Does Take Command Health help?
Yes. Each June, we provide:
An estimate of your average covered employees
Educational guidance on how to complete Form 720
The estimate and instructions are sent directly to your registered account email address each June. If you have not received them, check your Spam and Junk folders. If they are still missing, contact Customer Experience (CX) — they can resend the estimate or confirm what was sent for your account.
Note: The estimate reflects data Take Command has on file. If your portal data appears incomplete or the counts seem incorrect, contact Customer Experience before filing.
For step-by-step instructions on calculating your fee, completing Form 720, and submitting payment to the IRS, see 'How to Calculate, File, and Pay the PCORI Fee' in the Help Center.
Common questions
My Take Command plan was cancelled 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 are responsible for PCORI for those months. Calculate your average covered lives using only the months the HRA was in effect and file Form 720 by July 31.
I didn't receive my June PCORI estimate. What should I do?
Check your Spam, Junk, and Promotions folders. If the email is not there, log in to the HRA Hub Admin Portal and go to the Documents tab — filter by the correct plan year. If the estimate is still not available, contact Customer Experience. They can resend the estimate or confirm whether your account data is complete enough to generate one.
My estimate shows a placeholder value or zero enrolled employees. Is that correct?
If your estimate shows zero covered employees or a placeholder value, your portal enrollment data may be incomplete. Contact Customer Experience before filing — they can review your account data and confirm or correct the covered-lives count used in your estimate.
When is my first PCORI filing due if I just started my HRA?
Your first PCORI filing is due July 31 of the year after your first plan year ends. The PCORI fee covers the prior plan year, so:
If your plan year ends December 31, 2025 (calendar year plan), your first filing is due July 31, 2026.
If your HRA started mid-2025 and your first plan year ends December 31, 2025, you still owe PCORI for the months the plan was active in 2025 — your first filing is still due July 31, 2026.
If your plan started in 2026, your first filing will not be due until July 31, 2027.
Take Command will send your covered-lives estimate and filing instructions each June once your first plan year is complete. If you are unsure when your first filing is due, contact Customer Experience with your plan start date.
Why might I not have been required to file in a prior year?
The most common reasons an employer was not required to file PCORI in a prior year are:
No employees were enrolled in the HRA at any point during that plan year — if average covered lives was 0, no filing was required.
The HRA plan started mid-year and the first plan year ended after the July 31 deadline for that calendar year, so the first filing was due the following July.
The account was set up late and no employees were actively participating before year-end.
If you are unsure whether you were required to file for a prior year, contact Customer Experience with your plan start date and enrollment history. They can confirm whether your account had any covered lives for that period.
PCORI document timing: when does it cover and when is it generated?
The PCORI document Take Command provides each June covers your prior plan year — for example, the document sent in June 2026 covers plan year 2025, and is used to file Form 720 by July 31, 2026.
The 2026 plan year PCORI document (for filing by July 31, 2027) will not be available until June 2027. If you are looking for a document for the current plan year in progress, it has not been generated yet — this is expected.
When filtering in the Admin Portal Documents tab, select the plan year the document covers (e.g., filter on 2025 to find the document used for the July 31, 2026 filing), not the calendar year you are currently in.
What if my covered-lives count seems wrong?
If your PCORI estimate shows a covered-lives count that doesn't match your records — for example, you had 12 employees in the plan but only 5 are counted — the discrepancy usually comes from the distinction between employees in the plan and employees who actually received reimbursements (i.e., submitted proof of coverage and had approved claims). Only employees with eligible, approved reimbursements during the plan year count as covered lives for PCORI purposes.
To verify: download the Enrollment Report from the Reports tab in the Admin Portal, filter by plan year, and compare approved-claims employees to your total roster. If the count still appears incorrect after reviewing, contact Customer Experience before filing — do not file using a count you believe is wrong.
Where exactly do I report the PCORI fee on Form 720?
Report the PCORI fee on Part II, IRS No. 133. Form 720 covers many types of federal excise taxes — if you see sections about fuel taxes or transportation, you have the right form. Scroll to Part II to find the PCORI fee line. For a full walkthrough, see 'How to Calculate, File, and Pay the PCORI Fee' in the Help Center.
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