"For Health Reimbursement Arrangements (HRA), you must first look at the integrated group health plan. If that plan is fully insured, then the employer must file the 720 and pay the $2.66 fee for plan years that end on or after October 1, 2020 through September 30, 2021 ... [This] fee is paid per employee, not per 'belly button.' If however, the underlying group health plan is self-funded then no separate 720 need be filed for the integrated HRA but rather one filing and fee for the self-funded group health plan is due, based on 'belly buttons,' not just employees."