Can a CPA File PCORI for Clients?

Yes. A CPA can absolutely file PCORI for clients, and it is one of the most natural fits for this compliance task.

Form 720 is a federal excise tax return, not an informational return like Form 5500. A CPA with proper client authorization can prepare, sign, and submit it on the employer’s behalf. That is standard tax representation.

A CPA can manage the full process when the client supplies accurate covered life data, plan year end dates, and a valid EIN. The fee calculation is simple: applicable rate × average covered lives. For calendar-year plans ending December 31, 2025, that rate is $3.84 per IRS Notice 2025-61.

Employers who self-fund their health plans, including level-funded arrangements, pay the PCORI fee directly. The carrier does not handle it. These are the clients who most often need a CPA to file PCORI for clients on their behalf, since Form 720 is tax territory. 

2)Businesses Offering HRAs, ICHRAs, or QSEHRAs

HRAs are treated as self-insured plans for PCORI purposes. If an employer pairs an HRA with a fully insured medical plan, the insurer handles the insured lives, but the employer still owes the PCORI fee for HRA participants, counting one life per enrolled employee. When the HRA is paired with a self-insured plan under the same plan sponsor and plan year, only one filing is required.

CPAs who file PCORI for clients should gather the following before touching the form.

1)Determining the Correct Covered Life Count

The IRS permits three PCORI Filing methods: Actual Count, Snapshot, and Form 5500. The client or TPA selects the method; the CPA documents it. For HRAs with a fully insured plan, count one life per employee: no dependents. For self-insured major medical plans, count everyone including spouses and dependents. A PCORI Fee Calculator helps verify the math quickly.

2)Identifying the Applicable PCORI Rate

Per IRS Notice 2025-61: plan years ending January–September 2025 = $3.47 per covered life. Plan years ending October–December 2025 = $3.84 per covered life. Non-calendar-year plan clients often land in the wrong bracket, confirm before calculating.

3)Gathering Form 720 and EIN Information

Form 720 needs the employer’s legal name, address, and EIN. Clients without an EIN can apply for an Employer Identification Number online through the IRS directly.

4)Reviewing Plan Year End Dates

The plan year end date drives the rate and determines whether the filing covers a full or short plan year. Short plan years still require a PCORI filing; confirm with clients whether any 2025 plan changes created one.

• Wrong rate applied - Non-calendar-year plans often get tagged with the wrong bracket.

• Undercounted lives - Dependents and COBRA participants must be included for self-insured medical plans.

• Missed HRA obligation - Clients with fully insured medical plans sometimes assume the carrier covers everything, forgetting the HRA triggers a separate employer filing.

• Late filing - Penalties under IRC Section 6651 reach 5% per month, capped at 25%. The deadline is July 31, 2026, with no extensions.

Filing PCORI fee online through Simple720 removes the manual work. It is an IRS-authorized e-file provider that auto-calculates the fee, supports bulk filings across multiple clients, and issues a timestamped confirmation immediately after submission, no paper, no math errors, no guessing on status.

Use this before submitting any client’s Form 720:

• Confirm the plan type is subject to PCORI (self-insured, HRA, ICHRA, QSEHRA, or level-funded)

• Obtain plan year-end date(s), including any short plan years

• Collect average covered lives using an IRS-approved method

• Apply the correct rate: $3.47 (Jan–Sep 2025) or $3.84 (Oct–Dec 2025)

• Verify EIN and legal business name

• Confirm HRA integration type — one filing or two

• Complete Part II, Line 133 of Form 720 / 

• Arrange payment via check, EFTPS, or direct debit

• Submit by July 31, 2026

• Retain records for at least four years

Conclusion

A CPA can file PCORI for clients, and for employers with self-insured plans, HRAs, or level-funded arrangements, having a CPA handle Form 720 is the right call. The CPA prepares and files; the employer owns the liability. Accurately covered life counts, the right rate, and the July 31 deadline are what matter most.

If you manage PCORI filings for multiple clients, Simple720’s PCORI Bulk Filing Portal for CPA's is built for exactly that: IRS-authorized, bulk-capable, and fast.

File your PCORI Fee Online for 2026 now with Simple720!