Transitional Reinsurance Forms due Nov. 15th. - Action required by Self-Funded plans

Deadline: Registration on pay.gov and submission of enrollment information must be completed by November 15th of each year. In addition, employers making two payments must complete the second payment by November 15th.

INTRODUCTION

The Affordable Care Act establishes a transitional reinsurance program to help stabilize premiums for coverage in the individual market during the years 2014 through 2016. The statute requires self-insured group health plans (both Grandfathered and Non-Grandfathered), or a third-party administrator (TPA) on behalf of the plan, to make contributions to support payments to individual market issuers that cover high-cost individuals.

For fully insured plans, the insurer is required to make the payment on behalf of an insured major medical plan.

WHAT YOU SHOULD KNOW

The transitional reinsurance program fee applies as of January 1, 2014 regardless of the plan year or policy year. Certain self-insured, self-administered plans are exempt from the reinsurance fees in 2015 and 2016. The reinsurance fee is considered a permissible expense of the plan for purposes of Title I of the Employee Retirement Security Act.

Self-insured group health plans are liable for the fee, although a plan may utilize a third-party administrator or administrative-services-only contractor for transfer of the contributions.

Employer Actions
Current
1. Determine which plans are subject to the reinsurance fee. Include plans that provide major medical coverage, including retiree-only plans.
2. Determine which individuals must be counted. Don’t forget to include persons with COBRA. You may exclude persons whose primary coverage is Medicare or another group health plan. (Your TPA may have information relevant to coordination of benefits.) You may also exclude individuals that reside in a U.S. Territory that has not established an Exchange.
3. Determine which counting methods you wish to use. Be consistent in the counting method you use during the calculation period. Make sure you are making and maintaining adequate records to support your covered lives calculation. Note that regulations require maintenance of records to support the covered life count for at least 10 years. For further explanation and examples of the various counting methods provided by the Department of Health & Human Services Centers for Medicare & Medicaid Services, Click here.
4. Determine whether you as the plan sponsor or your TPA will submit enrollment information and the payment as described below.
October 1st – November 15th
Perform covered lives calculation based on data from January 1st through September 30th.
On or Before November 15th
Go to www.pay.gov Report basic company information and contact information or login using existing credentials. Enter enrollment information on the ACA Transitional Reinsurance Program Annual Enrollment Form. Attach supporting documentation as required. Attest that the information is accurate. Schedule payment. Payment Schedule for 2015 One Payment $44.00 per covered life due no later than January 15, 2016 Two Payments $33.00 per covered life due no later than January 15, 2016 $11.00 per covered life due no later than November 15, 2016 Regardless of when payment is made, the 2015 payment calculation is based on the covered lives reported on or before November 15, 2015.
After Enrollment Submission
Follow the process provided to you on www.pay.gov after the submission of your report.

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Transitional Reinsurance Forms due Nov. 15th. – Action required by Self-Funded plans

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INTRODUCTION

WHAT YOU SHOULD KNOW

Go to www.pay.gov

Payment Schedule for 2015

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