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File PCORI Fee for Fully Insured Health Plans, Know What You Owe and File It Right

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What Is a Fully Insured Health Plan?

  • A fully insured health plan is one where the employer pays a fixed premium to an insurance carrier. The carrier issues the policy, manages claims, and assumes the financial risk.
  • For PCORI purposes, the carrier files and pays the fee on the underlying insured plan. The employer is not required to file for that coverage on its own.

Eligibility Criteria for Fully Insured Health Plans

01
Fully Insured Coverage Only: Carrier Files

When the only benefit involved is the fully insured plan itself, the carrier takes care of PCORI filing and payment. That cost is already built into the premium you're paying, so there's nothing extra to submit. Employers don't need to file a Form 720 for this coverage on its own.

02
HRA Integrated With a Fully Insured Plan: Employer Files

In the case of a fully insured medical plan that is coupled with an HRA, the PCORI fee will fall on the HRA (as a self-insured plan). The fully insured medical insurance plan falls on the insurer. The covered lives of the HRA plan are determined by the number of employees who participate in the HRA plan.

03
Dental- or Vision-Only HRA: Usually Exempt

HRA that covers only dental benefits or only vision benefits is considered to be an excepted benefit and does not incur any PCORI fees. Nonetheless, in cases where the program provides more than limited dental or vision benefits, it will cease to be an excepted benefit.

04
FSA Paired With a Fully Insured Plan: Employer May File

Health FSAs are generally treated as excepted benefits and are exempt from PCORI. However, if the FSA does not meet the requirements for excepted benefit status, such as when employer contributions exceed the greater of $500 or the employee’s salary reduction amount, the FSA may be treated as a group health plan.

Challenges Organizations Face With PCORI Compliance
For Fully Insured Health Plans

Assuming the Carrier Handles Everything

Carriers only cover the fully insured plan itself, not any HRA layered on top of it. Employers who assume otherwise tend to skip a filing they actually owe, and missing it brings IRS penalties and interest.

Filing on the Wrong Form 720

The IRS revises Form 720 every second quarter with new dates and rates, and filing on an outdated version is one of the more commonly penalized mistakes. Before submitting, check that the form reflects the correct plan year-end dates.

Miscounting Covered Lives

HRA filings count participating employees only, while self-funded plans count both employees and dependents. Mixing up the two changes the fee you owe, sometimes by a wide margin.

Two Plan Year Endings in One Calendar Year

A short plan year can leave you with two plan year endings landing in the same calendar year. Both still get reported on a single Form 720, and neither fee is prorated. The full amount is owed for each plan year separately.

The July 31 Deadline

There’s no extension and no grace period on July 31. The IRS has been actively enforcing this deadline with penalties and interest, and a late or incorrect filing only adds to what you owe.

Why File PCORI Fees for Fully Insured Health Plans Online

Faster than Paper

Electronic filings move through IRS processing much faster than paper ones. Paper submissions are also running into longer delays from IRS staffing constraints, which raises the odds of missing your deadline entirely.

File From Any Device, Any Time

There’s no office to visit, no printer to track down, and nothing to mail. Log in, enter your plan details, and submit from whatever browser you happen to have open.

Fewer Errors at Submission

Online platforms flag missing fields and formatting issues before you hit submit, so problems surface during filing instead of after the IRS has already received it.

Handle Multiple Plans in One Session

Batch filing lets you work through several HRAs or self-funded plans without re-entering the same data for each one.

Clear Filing Records

Every electronic submission leaves behind a dated, trackable record you can pull up later if questions come up.

Why File PCORI Fees for Fully Insured Health Plans With QuickFile720?

IRS-Authorized Portal

QuickFile720 is directly authorized by the IRS for Form Form 720 e-filing so every submission runs through a compliant, approved channel. You get real-time IRS acknowledgment on each filing instead of waiting to find out whether it went through.

Bulk Filing for Multiple Plans

Upload and process multiple filings in a single session, with downloadable templates that let you pre-load plan information instead of typing it in plan by plan.

AICPA SOC-Certified Security

The platform meets AICPA SOC standards for data security and privacy, so your plan information stays protected against unauthorized access.

Affordable Online Access

Filing through QuickFile720 costs less than running expensive compliance software, with pricing built to work for businesses of any size.

No Software to Download

Everything runs in your browser. There’s nothing to install, and it works on any device with an internet connection.

Excise Tax Specialists on Call

The platform is built by federal excise tax experts, so support comes from people who actually work in this space, not a general help desk.


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Know What You Owe. File It Right. Don’t Miss July 31.

If your organization pairs an HRA with a fully insured health plan, the PCORI filing is your responsibility.
QuickFile720 gives you a fast, secure, IRS-authorized way to file, accurately and on time.

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Frequently Asked Questions

Generally, no. For fully insured coverage, the insurance carrier calculates, reports, and pays the PCORI fee. If the employer also sponsors a self-insured HRA, the employer is responsible for the HRA’s PCORI fee and reports it on Form 720, due July 31.

For HRAs tied to calendar-year plans ending December 31, 2025, the rate is $3.84 per covered employee, due July 31, 2026. Plan years ending before October 1, 2025 carry a rate of $3.47.

QuickFile720 is an IRS-authorized portal that lets you file Form 720 online in minutes. It supports batch filing for multiple plans, includes downloadable templates, and provides real-time IRS acknowledgment. No software required.