Can a TPA File the PCORI Fee? Third-Party Form 720 Filing Explained
Who is actually liable for the PCORI fee
For an applicable self-insured health plan, the plan sponsor — typically the employer — is liable for the PCORI fee under IRC §4376. For a fully-insured plan, the insurance issuer pays it. Either way, the party that owes the fee is the responsible filer; hiring a TPA or preparer does not transfer that legal responsibility.
What a TPA or preparer can do for you
- Calculate your average covered lives using an approved method
- Prepare the second-quarter Form 720 with IRS No. 133 completed
- E-file the return on your behalf with authorization
- Maintain records and reminders for the annual July 31 deadline
What it cannot do is assume your liability. If the fee is wrong or late, the IRS looks to the sponsor — so review what your TPA prepares before it's filed.
How third-party filing works on EasyFile720
Preparers and TPAs can manage multiple businesses and EINs from one dashboard, with separate filings and records per client. Count covered lives (or import them), let the workflow select the correct line 133(a)–(d) and rate, and e-file — for one plan or for dozens. New to the fee? Start with our PCORI fee filing guide or the covered-lives counting methods.
FAQ
Can a TPA file the PCORI fee for a self-insured plan?▼
A third-party administrator can prepare and e-file Form 720 on the plan sponsor's behalf when authorized, but the plan sponsor remains legally responsible for the PCORI fee. For most self-insured group health plans the sponsor (the employer) — not the TPA — is liable for the fee and the filing.
Does a TPA have to pay the PCORI fee out of plan assets?▼
Generally the plan sponsor pays the PCORI fee, and for a self-insured plan it is typically treated as a sponsor expense rather than paid from plan assets. A TPA may calculate covered lives and facilitate the filing, but it does not assume the sponsor's legal liability.
Can a CPA or payroll provider e-file Form 720 for me?▼
Yes. A CPA, enrolled agent, payroll provider, or other paid preparer can prepare and electronically file Form 720 for you with proper authorization. The business that owes the excise tax is still the responsible party for accuracy and payment.
How does EasyFile720 support preparers and TPAs?▼
EasyFile720 lets a preparer or TPA manage multiple businesses and EINs from one dashboard, with separate filings and records per client, so you can file IRS No. 133 (and any other Form 720 taxes) for many clients in one place.
Filing PCORI for clients?
Manage every client's Form 720 from one EasyFile720 dashboard — separate EINs, separate records, IRS-authorized e-file for IRS No. 133.
Reflects the PCORI fee rules under IRC §§ 4375–4377 and the Instructions for Form 720 (Rev. June 2026). General information, not tax or legal advice. Confirm liability and authorization specifics with a qualified advisor.
