In 2014, 2015 and 2016, health insurers of fully-insured plans and employer plan sponsors of self-insured plans must pay a Transitional Reinsurance Fee to help stabilize premiums in the individual market. The plans subject to the fee are limited to primary coverage major medical plans only and do not include excepted benefits such as stand-alone dental, vision, or prescription drug plans, HSAs, FSAs, integrated HRAs, Medicare Advantage plans or major medical coverage that is secondary to other individual or group medical coverage including Medicare.
The fee for 2014 was $63.00 ($5.25 per month) per covered life. For 2015, the fee will decrease to $44.00 ($3.67 per month) per covered life, and the fee should decrease further for 2016. Covered lives include all enrollees on the plan such as employees, dependents, retirees and COBRA participants as long as the coverage is primary. The fee is based on calendar year, not plan year, and the formula used to calculate covered lives is generally based on enrollment in the first 9 months of the calendar year.
In November of the filing year, all health insurers of fully-insured plans and employer sponsors of self-insured plans must report basic company contact information and enrollment counts to the Department of Health & Human Services (HHS) by using the “ACA Transitional Reinsurance Program Annual Enrollment and Contributions Submission Form” at www.pay.gov. The form will auto-calculate the fee, and filing entities may schedule a date for payment remittance for January of the following year. Although employer plan sponsors of self-insured plans are ultimately responsible for reporting and remitting the Transitional Reinsurance fee, they may authorize TPAs or ASO providers to submit on their behalf. No action is required of employer plan sponsors of fully-insured plans as their health insurer will file and pay the Transitional Reinsurance fee on their behalf.
Group Alternatives will provide all client plan sponsors of self-insured plans with the number of covered lives necessary for submitting the ACA Transitional Reinsurance Program Annual Enrollment and Contributions Submission Form, along with the required Supporting Documentation and step-by-step instructions for filing in early October of each reporting year.