2016 Transitional Reinsurance Fee Submission Due Nov. 15

By Richard Stover and Kimberley Mitchell Oct 14, 2016
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The deadlines for the 2016 transitional reinsurance fee are approaching. To determine the amount of the 2016 reinsurance fee, insurers or self-insured group health plan sponsors must submit plan enrollment counts to the federal Centers for Medicare & Medicaid Services (CMS) by Nov. 15. Also, the second contribution for the 2015 reinsurance fee must be made by that date.


The Affordable Care Act's transitional reinsurance program was designed to help stabilize premiums in the individual market, both inside and outside the public marketplaces. Insurers and sponsors of self-insured group health plans must make contributions to the program for the 2014, 2015 and 2016 calendar years. The fees are:

  • $63 per covered life for 2014.
  • $44 per covered life for 2015.
  • $27 per covered life for 2016.

Self-insured health plan sponsors submit covered lives data and make payments through the Pay.gov website. CMS released a memo on Sept. 19 that announced the 2016 submission process. CMS also released an Annual Enrollment and Contributions Form Manual and a Quick Start Guide.

Submission of 2016 Enrollment Count

CMS uses the annual enrollment count to calculate an entity's contribution amount due for the applicable year. Plan sponsors have a choice of four counting methods, which are unchanged from previous years. The counting methods are:

  • Actual count.
  • Snapshot count.
  • Snapshot factor.
  • Form 5500.

Plan sponsors may use different counting methods for their various plans and may also use a different counting method than used for past years.

Under all alternatives, except the Form 5500 method, the number of covered lives for 2016 will be determined based on the first nine months of the 2016 calendar year.

For 2016, the enrollment count submission is due by Tuesday, Nov. 15. Plan sponsors must use the 2016 ACA Transitional Reinsurance Program Annual Enrollment and Contributions Submission Form on Pay.gov to submit their enrollment count. The form will auto-calculate the contribution amount owed based on the 2016 rate of $27 per covered life.

The amount due may be paid in one payment, due by Jan. 17, 2017, or in two, the first of which is due by Jan. 17, 2017 and the second by Nov. 15, 2017.

Key Deadlines

Date Activity Contribution Amount
No later than Nov. 15, 2016Submit 2016 enrollment count and schedule paymentsN/A
No later than Jan. 17, 2017

Remit first contribution amount for 2016 benefit year

The full contribution can be made in a single payment by this date

$21.60/covered life

$27.00/covered life (if paying full contribution amount)

No later than Nov. 15, 2017Remit second contribution amount for 2016 benefit year$5.40/covered life


Second 2015 Contribution Due by Nov. 15

Self-insured plan sponsors had the option of paying the 2015 contribution in one payment or in two separate payments. For plan sponsors who chose to pay the 2015 contribution in two payments, the second payment of $11 per covered life is due no later than Nov. 15, 2016.

The second payment date was already scheduled by plan sponsors with the submission of the 2015 enrollment count. The payment must be made using an Automated Clearing House (ACH) debit on Pay.gov. Plan sponsors should ensure that they have sufficient funds in their account for this payment and that the automatic ACH debit will not be blocked by the bank.

In Closing

For purposes of paying the second 2015 contribution amount, plan sponsors should confirm that adequate funds will be in the payment account on the payment date. Also, for the 2016 contribution, once covered lives information is available through September 2016, plan sponsors will be able to determine their enrollment count and prepare the submission for 2016.

Richard Stover, FSA, MAAA, is a principal and actuary at Xerox HR Services. Kimberley Mitchell, JD, is a director in the Knowledge Resource Center at the firm. This article originally appeared in the Oct. 13, 2016 issue of For Your Information, produced by the Knowledge Resource Center at Xerox HR Services. © 2016 Xerox Corp. All rights reserved. Republished with permission.

Related SHRM Article

PCORI & Reinsurance Fees—Keeping Them Straight, SHRM Online Benefits, updated November 2014 

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