PCORI Fee for Self-Insured Plans, HRAs & FSAs
Self-funded medical plans
If you sponsor an applicable self-insured health plan, IRC §4376 makes you — the plan sponsor, typically the employer — liable for the PCORI fee. You report it on Form 720 lines 133(c) or 133(d) depending on your plan-year-end date, at $3.84 per average covered life for plan years ending Oct 1, 2025 – Sep 30, 2026. There's no EFTPS deposit; you pay with the second-quarter return by July 31. Full detail in our self-insured plans guide.
HRAs: yes, with a friendly counting rule
Most Health Reimbursement Arrangements are themselves applicable self-insured health plans, so they owe the PCORI fee. The break: for an HRA you may count one covered life per participating employee — you don't count spouses or dependents. So an HRA covering 200 employees is 200 lives × $3.84 = $768, regardless of family size.
Health FSAs: usually exempt
A health FSA generally escapes the PCORI fee when it qualifies as an excepted benefit. It typically qualifies when both are true:
- You also offer other group health coverage (not just the FSA); and
- The maximum FSA benefit doesn't exceed two times the employee's salary reduction (or the salary reduction plus $500).
Meet the test → the FSA is an excepted benefit and not subject to PCORI. Fail it (for example, a large employer-funded FSA with no underlying plan) → it can be a self-insured plan that owes the fee.
Fully-insured plan plus an HRA
A common setup: a fully-insured major medical plan with an employer HRA on top. Here the insurer pays the PCORI fee on the insured policy, and you pay separately on the HRA — but only one life per participant. It feels like paying twice; it isn't — they're two different plans, and the HRA piece stays small.
FAQ
Do self-insured health plans owe the PCORI fee?▼
Yes. The sponsor of an applicable self-insured health plan — usually the employer — is liable for the PCORI fee under IRC §4376. For 2026 the rate is $3.84 per average covered life for plan years ending Oct 1, 2025 – Sep 30, 2026, reported on Form 720 line 133(c) or 133(d).
Are HRAs subject to the PCORI fee?▼
Yes. Most Health Reimbursement Arrangements are treated as applicable self-insured health plans and owe the PCORI fee. You may count one covered life per participating employee — spouses and dependents are not counted separately for an HRA.
Are health FSAs subject to the PCORI fee?▼
Usually not. A health FSA that qualifies as an "excepted benefit" is exempt from the PCORI fee. It generally qualifies if the employer also offers other group health coverage and the FSA benefit does not exceed two times the employee's salary reduction (or the salary reduction plus $500). FSAs that fail the excepted-benefit test can be subject to the fee.
If I have a fully-insured plan plus an HRA, do I pay PCORI twice?▼
The insurer pays the PCORI fee on the fully-insured policy. You, the employer, separately pay the fee on the HRA because it is its own self-insured plan — but you can count one life per participant, which keeps the HRA portion small.
File your self-insured PCORI fee
EasyFile720 supports PCORI-only filers — pick your plan type, enter covered lives, and we select the right line and e-file IRS No. 133 to the IRS.
This article reflects IRS Notice 2025-61, the Instructions for Form 720 (Rev. June 2026), and the PCORI regulations under IRC §§ 4375–4377. The excepted-benefit FSA analysis is fact-specific — confirm your arrangement with a qualified advisor. General information, not tax advice.
