When most people think about PCORI compliance, they picture an employer’s HR team scrambling to meet a July 31 deadline. What they don’t picture is the TPA quietly working behind the scenes, calculating covered lives for 40 different employer clients, coordinating EFTPS payments, and making sure none of them get an IRS notice in October.
If you’re a Third-Party Administrator, that’s your world. And the scale problem is real.
This post is for TPAs who want to understand their role in the PCORI ecosystem more clearly, and for those who are still managing this process manually and wondering if there’s a better way.
What Is a TPA’s Role in PCORI Filing?
The PCORI fee is legally owed by the plan sponsor, which is the employer who maintains the self-insured health plan. But in practice, most self-insured employers rely on their TPA to handle the administrative side of compliance, including PCORI.
That relationship typically looks like this:
- The employer provides enrollment data covering employees and their dependents
- The TPA calculates the average covered lives using one of the IRS-approved methods
- The TPA completes IRS Form 720, Schedule B, on behalf of the employer
- The filing is submitted under the employer’s EIN, not the TPA’s
- Payment is made via EFTPS, often coordinated by the TPA
Critically, even when a TPA handles all the legwork, the legal liability for accuracy and timeliness stays with the employer. That means a TPA’s errors become the employer’s problem, and by extension, a relationship problem. Getting this right isn’t just a compliance matter; it’s a client retention matter.
The Scale Problem: Why Manual Processes Break Down
For a TPA managing three or four self-insured employer clients, a spreadsheet-based approach might be workable for now. But the math gets unfavorable fast.
Consider what manual PCORI management looks like at scale:
- Data collection: reaching out to each employer client for enrollment figures, chasing down responses as the July 31 deadline approaches
- Covered lives calculation: applying the snapshot, actual count, or snapshot factor method for each client individually, with different plan year end dates adding complexity
- Rate verification: checking the current IRS Notice for the applicable fee rate, which changes annually, and applying the right rate to each plan year
- Form 720 preparation: completing Schedule B for each client, ensuring the correct EIN is used, and keeping each filing properly separated
- Payment coordination: ensuring each employer’s EFTPS payment is submitted correctly and tied to the right tax period
- Recordkeeping: maintaining documentation of covered lives calculations, fee computations, and filing confirmations for potential IRS review
Multiply that across 30, 50, or 100 employer clients and you have a significant operational burden, one that scales linearly with your client base and creates compounding risk with every manual step.
The most common failure points? Missed deadlines when one client’s data arrives late, calculation errors when fee rates are applied to the wrong plan year, and payment or filing mismatches that generate IRS CP162 notices.
The Compliance Stakes for TPAs
It’s worth being precise about where TPA liability begins and ends in the PCORI context.
TPAs are not the legal filer. They are acting as authorized agents of the plan sponsor. That means:
- The IRS will contact the employer, not the TPA, when there is a compliance problem
- Penalties accrue to the employer’s EIN, including failure-to-file and failure-to-deposit penalties, plus interest
- The TPA’s exposure is contractual. If the service agreement includes PCORI filing as a covered service, errors can create professional liability and client disputes
This dynamic puts TPAs in an interesting position: they bear operational responsibility without direct regulatory liability. The practical result is that a TPA’s reputation is only as good as its most recent filing season. One missed deadline for a major client can undo years of goodwill.
What Good TPA PCORI Workflows Look Like
The TPAs who handle PCORI most effectively, regardless of client volume, share a few common practices:
Centralized client data management. Rather than collecting enrollment data reactively in June, high-performing TPAs build quarterly data pulls into their standard workflow so covered lives figures are current and available well before the deadline.
Standardized calculation methodology. Choosing one IRS-approved method, typically the snapshot method, and applying it consistently across all clients reduces calculation variance and simplifies documentation. Deviations for specific clients should be documented and justified.
Separated filing records by EIN. Every employer client is a separate filer. Maintaining clean, separated records for each, including the covered lives calculation, the applicable fee rate, the Schedule B detail, the filing confirmation, and the EFTPS payment record, is essential for responding to any future IRS inquiry.
Advance deadline management. July 31 is fixed, but data collection and calculation can begin in May. TPAs that build a 60-day pre-deadline workflow protect themselves from the last-minute scramble that causes errors.
Written filing authorization. A clear engagement letter or service agreement addendum that specifies PCORI filing as a covered service, and outlines the employer’s responsibility to provide accurate enrollment data, protects both parties and sets clear expectations.
The ROI of Purpose-Built TPA Filing Software
There is a straightforward business case for TPAs who handle PCORI at any meaningful scale to move away from manual processes.
At 10 clients, the time cost of manual PCORI management might be two or three full days of staff time each year, which is annoying but manageable. At 50 clients, that same approach can consume weeks of capacity during an already-busy Q2, with materially higher error risk.
Purpose-built e-filing platforms designed for TPA workflows, like Akore Federal, address this directly:
- Multi-client dashboard: manage all employer clients from a single interface, with filing status visible across your entire book
- Built-in fee rate updates: the current IRS rate is always current with no manual Notice lookup required
- Covered lives calculator: input enrollment data and the platform applies the correct method and rate automatically
- EIN-level separation: each filing is correctly attributed to the employer’s EIN, with separate records and confirmations
- Integrated IRS e-submission: direct filing with IRS acknowledgment receipt, not a paper form in the mail
- Audit trail: every calculation, filing, and payment is logged and retrievable
The result is a PCORI filing season that takes hours, not weeks, with documentation that holds up to scrutiny and clients who never see a late-filing penalty.
Positioning PCORI Filing as a Value-Added TPA Service
There is also a commercial angle worth considering. Most self-insured employers either don’t fully understand their PCORI obligation or don’t want to deal with it. TPAs that handle this seamlessly, proactively, accurately, and with clear documentation, are providing genuine value that strengthens the client relationship.
TPAs who are not currently offering PCORI filing as part of their service package may be leaving a client expectation unmet. Employers who don’t receive PCORI support from their TPA often turn to their CPA, and that is a missed touchpoint for the TPA.
Framing PCORI management as a compliance service line, rather than an administrative afterthought, positions the TPA as a more complete compliance partner. That framing supports retention conversations, justifies service fee structures, and differentiates from competitors who treat PCORI as a footnote.
Scale Your PCORI Filings with Akore Federal
Akore Federal is built for TPAs who need to manage PCORI filings across a large employer client base, accurately, efficiently, and with a clean audit trail for every filing.
Whether you’re handling 10 clients or 200, our platform eliminates the manual spreadsheet workflow and replaces it with a centralized, IRS-integrated filing system designed for the way TPAs actually work.
Start filing for your clients at AkoreFederal.com
Managing PCORI for a large book of self-insured clients? Contact our TPA solutions team to learn how Akore Federal can be integrated into your existing compliance workflow.
