Transitional Reinsurance Fee Roundup: That $63 per head fee, Delayed. Now Due 12/05/2014
Update, Sunday, Nov 16, 2014: The Department of Health and Human Services 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.
What is it?
The Reinsurance Assessment is a fee applicable to insured and self-funded major medical plans for calendar years 2014 through 2016. It will primarily be used to help cover the cost of high-dollar claims occurring within the individual market. The 2014 fee is $63 per person, which the updated regulation proposes to collect in two installments: $52.50 in January 2015, and $10.50 late in the fourth quarter of 2015. (Reports due 11/15/2014, HHS’ bill comes 12/15/2014, bills due in installments; typically from your ASO-claims payer to HHS). For 2015, the proposed fee is $44 per person. See our prior guidance (and details) on this topic from March 6, 2013 and Dec 13, 2012.
When is it due? And, can HHS offer any help?
HHS just released their Until then, I wanted to make sure that everyone saw that HHS has released the Annual Enrollment and Contributions Submission Form Manual (64 pages) and a Supporting Documentation Job Aid Manual (14 pages) in anticipation of the release of the form (now expected to be Thursday, October 24, 2014). **See this handy list of FAQs – this will assist you in completing your filing!
In light of the fact that the November 15th deadline is a Saturday in 2014, HHS states (in an FAQ) that self-funded plans (aka contributing entities) may submit their enrollment count by Monday, November 17th this year. Of course no one will wait that long because Pay.gov is bound to experience bottleneck-issues as the deadline approaches.
Does my plan year matter? No, it does not. This is a calendar year fee (tax) on all self-funded plans.
- HHS Annual Enrollment and Contributions Submission Form Manual released 10/20/2014 (64 pages)
- HHS Supporting Documentation Job Aid Manual released 10/20/2014 (14 pages)
Prior guidance/postings on this topic:
- July 22, 2014: bswift ACA Management Suite
- Nov 27, 2013: Holiday Regulation Dump! That Pesky $63 per head fee and Much More!
- March 6, 2013 and Dec 13, 2012: HHS Guidance New PPACA $63 Per Head Fee