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.
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.
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
Does the PCORI fee apply to QSEHRA and ICHRA?
Yes. According to the IRS, the PCORI fee applies to the sponsors of applicable self-insured health plans, which includes Qualified Small Employer HRAs (QSEHRA) and Individual Coverage HRAs (ICHRA).
For QSEHRA and ICHRA, the employer (plan sponsor) is responsible for reporting and paying the PCORI fee.
The fee is based on the average number of covered employees (not spouses or dependents) who have not waived coverage during the plan year.
This fee does not apply to fully insured health policies (those are handled by the insurer) but does apply to self-insured arrangements like QSEHRA and ICHRA.
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
Note: Although Form 720 is a quarterly return, for PCORI, Form 720 is filed annually only, by July 31. If you have another reason to file Form 720 on a quarterly basis, you only need to report the PCORI fee on the second quarter form, due July 31st.
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