Transitional Reinsurance Reporting Deadline Is Nov. 15

Self-insured plans must report annual enrollment based on first nine months of the year

By Stephen Miller, CEBS Nov 7, 2014
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For 2014, Reporting Deadline Extended to Dec. 5

For 2014, the Nov. 15 deadline for self-insured health plans to report their annual enrollment count under the Affordable Care Act’s Transitional Reinsurance Program was extended to Dec. 5, the Department of Health and Human Services/Centers for Medicare & Medicaid Services announced on Nov. 14, in a posting on the website. The posted alert is shown below:

Alert Message (effective 11/14/2014): Attention ACA Transitional Reinsurance Reporting Entities: CMS has received requests for an extension of the deadline for contributing entities to submit their 2014 enrollment counts for the transitional reinsurance program contributions under 45 CFR 153.405(b). The deadline has now been extended until 11:59 p.m. on December 5, 2014. The January 15, 2015 and November 15, 2015 payment deadlines remain the same. If you have any questions regarding the ACA Transitional Reinsurance Program Annual Enrollment Contributions Submission form, please contact the Health and Human Services (HHS) Centers for Medicare & Medicaid Services (CMS) directly at 1-855-267-1515, opt. 3, then opt. 4, or e-mail

Nov. 15 is the annual deadline for self-insured health plans to report their annual enrollment count—based on the first nine months of the year—under the Affordable Care Act’s Transitional Reinsurance Program (TRP).

Because Nov. 15 falls on Saturday this year, law firm Warner Norcross & Judd LLP is advising that group health plans must report the number of individuals covered by Nov. 17.

Annual enrollment and contributions submission forms are available on, as explained in an announcement by the Centers for Medicare and Medicaid Services.

In order to successfully complete the annual reinsurance fee submission, self-insured plan sponsors or their representatives need to: (1) Register on; (2) Fill out the Transitional Reinsurance Form; (3) Attach a supporting documentation file; and (4) Schedule a reinsurance payment, reminds an alert from law firm Alston & Bird LLP.

Within 30 days of submission of the annual enrollment count or by Dec. 15, whichever is later, the Department of Health and Human Services (HHS) will notify the contributing entity of the reinsurance fee to be paid for the applicable benefit year. Payment is due within 30 days of the date of this notification.

Self-Insured plans are responsible for the reinsurance contributions but may elect to use a third-party administrator or administrative-services-only contractor to transfer the reinsurance fee. For fully insured plans, the insurance issuer is responsible for the reinsurance fee.

Fee Calculation

The fee will apply to calendar years 2014, 2015 and 2016. The annual reinsurance fee for 2014 will be $63 ($5.25/month) per covered life. The $63 rate is a national uniform contribution rate and does not vary by state. However, states may elect to collect more than the amount that would be required under the national contribution rate to provide funding for administrative expenses or additional reinsurance payments.

On March 5, 2014, HHS released a final rule clarifying, among other things, that employers will be allowed to pay the transitional reinsurance fee in two annual installments. Self-insured plan sponsors can make one payment (due Jan. 15, 2015) or two installment payments ($52.50 per covered life, due Jan. 15, 2015; and $10.50 per covered life, due Nov. 15, 2015).

“Several methods are available for determining the annual enrollment count for purposes of the TRP fee,” according to an alert from consultancy PwC. “These methods are similar to those used to determine the PCORI fee, but are based on the first nine months of the calendar year, rather than the plan year. Plans may make an actual count of covered enrollees on each day of the first nine months of the year, and divide by the number of days, or may use a snapshot method or a method based on the numbers filed in the plan’s Form 5500 Annual Report.”

For every state, all of the contributions from the self-insured market will be collected by HHS even if the state has a state-operated reinsurance program.​

TRP Rates for 2015 and 2016

The IRS has proposed ​a $44-per-participant fee for 2015 and a $27-per-participant fee for 2016:

  • The 2015 fee of $44 per participant could be paid in full by Jan. 15, 2016, or with a $33 payment made by Jan. 15, 2016, and an $11 payment made by Nov. 15, 2016.
  • The 2016 fee could be paid in full by Jan. 15, 2017, or with a $21.60 payment made by Jan. 15, 2017, and a $5.40 payment made by Nov. 15, 2017.

Stephen Miller, CEBS, is an online editor/manager for SHRM. Follow him on Twitter @SHRMsmiller.

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