The IRS's quiet Form 720 update

ICYMI: the IRS updated the Form 720 Friday night. Quietly too. No announcement from the Service that I can find. They just swapped it out at the permanent link.

32 days until it’s due for plans that ended in 2025.

Fully insured only? You’re done. The insurer calculates and files your PCORI fee. Scroll on.

Self-funded, level-funded, or HRA (including ICHRA)? This one’s yours. Keep reading.
PCORI fees for self-funded plans, including HRAs, are the obligation of the plan sponsor, usually the employer. For some level-funded plans the carrier or TPA handles the filing, so confirm who owns it before you assume it’s on you.

If your plan ended between 1/1/25 and 9/30/25, the fee is $3.47 per covered life.

If your plan ended between 10/1/25 and 12/31/25, the fee is $3.84 per covered life.

If the plan started in 2025 and ends in 2026, you pay next year.

Counting covered lives is the tricky part with three methods for self-funded plans:

1. Actual count method
Add everyone covered on every day of the plan year and divide by the days in the plan year. Almost nobody uses this.

2. Snapshot method
Same idea, simplified. Pick consistent dates each quarter and use only those.

3. Form 5500 method
If your plan covers dependents, which is most major medical, add your PY start and PY end participant counts and do not divide by two. If your plan only covers employees, like most standalone HRAs, add them and divide by two. You have to file your 5500 by 7/31 to use this one.

A couple of nuances. An HRA integrated with a self-funded plan from the same sponsor only counts each covered life once. A standalone HRA, or one integrated with a fully insured plan, counts participants only.
One more now that the form is live. The IRS revises the second quarter 720 more than once during the quarter, so check that Line 133 shows the right dates and amounts before you file.

The form is out, so it’s time to figure out your counts. The “we’ll wait for the form” window just closed.