Transitional Reinsurance Fee Deadlines Approaching

By Kimberley Mitchell, JD, and Richard Stover © Buck Consultants Oct 1, 2015
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For updated information regarding plan year 2016 fees and filings, see the SHRM Online article 2016 Transitional Reinsurance Fee Submission Due Nov. 15.


The deadlines for the Affordable Care Act’s (ACA’s) 2015 transitional reinsurance fee are approaching. Enrollment counts for purposes of determining the 2015 reinsurance fee must be submitted by Nov. 16. Also, the second contribution for the 2014 reinsurance fee must be made by Nov. 15.

Background

The transitional reinsurance program was designed to help stabilize premiums in the individual market, both inside and outside the ACA’s 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 and $27 per covered life for 2016. Plan sponsors submit covered lives data and make payments through pay.gov.

Year

Reinsurance Rate

(per plan enrollee)

2014

$63

2015

$44

2016

$27



The Centers for Medicare & Medicaid Services (CMS) has provided a summary of the program provisions and resources.

Second 2014 Contribution Due by Nov.15

Plan sponsors had the option of paying the 2014 contribution in one payment or in two separate payments. For plan sponsors who chose to pay the 2014 contribution in two payments, the second payment of $10.50 per covered life is due no later than Nov. 15, 2015. The second payment date was already scheduled by plan sponsors with the submission of the 2014 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.

Enrollment Count for 2015 Submission Due Nov. 16

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. They may use different counting methods for their various plans and may also use a different counting method than that used for 2014.

The counting methods are the same as last year:

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

Under all alternatives except the Form 5500 method, the number of covered lives for 2015 will be determined based on the first nine months of the 2015 calendar year.

For 2015, the enrollment count submission is due by Monday, Nov.16. Plan sponsors must use the “2015 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 2015 rate of $44 per covered life. The 2015 Submission Form will be available on pay.gov on Oct. 1, 2015.

The submission and payment process is largely unchanged from last year, with the exception that most employers will no longer need to submit the supporting documentation that was required in 2014. The amount due may be paid in one payment, due by Jan. 15, 2016, or in two payments, the first of which is due by Jan. 15, 2016 and the second by Nov. 15, 2016.

Key Deadlines

Date

Activity

Contribution Amount

Oct. 1, 2015

2015 ACA Transitional Reinsurance Program Annual Enrollment and Contributions Submission Form available on pay.gov.

N/A

No later than Nov. 15, 2015

Remit second contribution amount for 2014 benefit year.

$10.50/covered life

No later than Nov. 16, 2015

Submit 2015 enrollment count and schedule payments.

N/A

No later than Jan. 15, 2016

Remit first contribution amount for 2015 benefit year.

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

$33/covered life.

$44/covered life (if paying full contribution amount.

No later than Nov. 15, 2016

Remit second contribution amount for 2015 benefit year.

$11/covered life.

Source: Buck Consultants


In Closing

For purposes of paying the second 2014 contribution amount, plan sponsors should confirm that adequate funds will be in the payment account on the payment date. Also, for the 2015 contribution, once covered lives information is available through Sept. 2015, plan sponsors will be able to determine their enrollment count for 2015 and prepare the 2015 submission.

Kimberley Mitchell, JD, is a director in the Knowledge Resource Center of Buck Consultants, a Xerox Company. Richard Stover, FSA, MAAA, is a principal and actuary at Buck Consultants. This article originally appeared in the Sept. 25, 2015 issue of For Your Information, produced by Buck Consultants’ Knowledge Resource Center. © 2015 Xerox Corp. and Buck Consultants. All rights reserved. Republished with permission.

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