by Lisa Klinger, J.D. and Susan Grassli, J.D.
Sponsors of self-insured group health plans must register on Pay.gov, submit enrollment information (number of “covered lives” during the first nine months of 2014), and schedule payment dates by December 5, 2014. Actual payment is not required until 2015, but the dates must be scheduled by December 5. The first installment of the transitional reinsurance fee must be paid by January 15, 2015, and the second is due by November 15, 2015. (Alternatively, a plan sponsor can make one combined (full) payment by January 15, 2015.) This article explains the process.
As background, the Transitional Reinsurance Program was created by the Affordable Care Act (ACA) section 1341 to help stabilize premiums in the individual market in 2014-2016. It is intended to collect $25 billion in fees from group health plans during 2014-2016 to partially reimburse insurers in the individual Exchange/Market who cover high-cost individuals. The annual fee for 2014 is $63.00 per covered life (enrolled employees and dependents).
For self-insured plans the plan sponsor is the “contributing entity” and is responsible to pay the fee. Most third party administrators (TPAs) are helping with this process by providing enrollee counts, but it is the employer who sponsors a self-funded plan that must go online to pay.gov to register and pay the reinsurance fee. For insured plans, the carrier must pay the fee, so employers that sponsor insured group health plans need not go online to pay.gov (to register or to pay).
Important Note: There are several different acceptable ways to calculate the number of “covered lives.” If you have a lot of plan participants who cover large families, you may want to use the “Snapshot Factor” method rather than the other methods, since this calculates the enrollee count based on the actual number of employees with self-only coverage plus 2.35 times the number of participants with other than self-only coverage (in essence, counting large families as only 2.35 enrollees).
Only “major medical” plans are required to pay the reinsurance contribution. It does not apply to “excepted benefits” (such as stand-alone dental or vision plans, hospital indemnity); Health FSAs; Employee Assistance Programs (EAPs); or HRAs and HSAs that are integrated with high-deductible health plans (HDHPs).
How to Pay the Transitional Reinsurance Fee
“Contributing entities” must complete the following steps. More detail on each step is provided below, and there is a long instruction manual on the Pay.gov website (URL is listed at the end of this article).
- Register on Pay.gov
- Access and complete contribution form on Pay.gov, entitled “ACA Transitional Reinsurance Program Annual Enrollment and Contribution Submission Form,” to report the average number of enrollees during the first nine months of the calendar year.
- Upload the Supporting Documentation. This document must be in the CSV format (comma-separated values). Before you even register on Pay.gov, you may want to download the following file, and input the required information in the file layout specified, so your supporting documentation will be ready to upload when you get to this step: http://www.cms.gov/CCIIO/Programs-and-Initiatives/Premium-Stabilization-Programs/The-Transitional-Reinsurance-Program/Downloads/Supporting-Documentation-File-Layout-Requirements.pdf This is repeated below in the details on Step 3. When you upload the information, it must be in the CSV format that meets the specified file layout requirements.
- Enter payment information. Select type of payment, specify a payment date and enter banking information.
1- Register on Pay.gov
Register or Log in, at the top right. If you have previously registered, click on “My Profile” to ensure the information is correct, because this information pre-populates on the ACA Transitional Reinsurance Program form that you will complete in the next step. If you open the Form before you have logged in, the form will not pre-populate, and you will have to log in before you can submit the form.
2- Access and Complete Contribution Form on Pay.gov
The form is entitled “ACA Transitional Reinsurance Program Annual Enrollment and Contribution Submission Form,” and is used to report the average number of enrollees during the first nine months of the calendar year.
To find the form on Pay.gov: In the search box in the upper left type “ACA” or “transitional reinsurance fee.” The ACA Transitional Reinsurance Program form should be the first one. It will be pre-populated with the plan sponsor or “contributing entity” name (from information in “My Profile”) and the tracking number.
Input requested employer information that is not already pre-populated. The form asks for three contacts and will require at least two different ones; if you don’t have three, you can re-enter the first one as the third one also. For enrollee counts, you should have received information from your TPA.
Under “Type of Payment” select either “First Collection” ($52.50/enrollee due by January 15, 2015), “Second Collection” ($10.50/enrollee due by November 15, 2015), or “Combined Collection” ($63/enrollee due by January 15, 2015). Do not select “Invoice” option when you are doing your first submission. Select this option only if you need to re-submit information after being notified to do so by Pay.gov.
Important Note: If you only select First Collection (as most employers probably are), you must also go back and select Second Collection right after you submit the form. Both payments must be scheduled by December 5, 2014, even though the Second Collection is not due until November 15, 2015.
Other lines to complete:
- “Benefit Year for Reporting” is 2014.
- “Total Applicable. . .Contribution Rate” is $63.00
- “Gross Enrollment Count” is the number of enrollees
- “Contribution Rate for Program Payments and Program Administration Funds” is $52.50 for 2014
- “Contribution Rate for General Fund of the US Treasury” is $10.50 for 2014
The form auto-calculates the contribution amounts due (two sub-amounts plus the total), based on the enrollment count, benefit year and the type of payment selected (i.e., First, Second or Combined).
You do not need to input Pay.gov tracking ID in your first form. You only need it if you re-file later.
Click the two boxes at the bottom of this page. One states that the gross annual enrollment count entered in this form matches the count in the supporting documentation and the other is an Acknowledgment agreeing to the terms. Enter your name, title and contact information, the click “the continue” button.
Please note that if you have questions at any time, you can click the “Need Help?” button.
3- Upload the Supporting Documentation
As recommended above, even before you register on Pay.gov and complete the Contribution Form, you should download the following file and input the required information in the file layout specified. This is the “Supporting Documentation Job Aid Template” available from the government at http://www.cms.gov/CCIIO/Programs-and-Initiatives/Premium-Stabilization-Programs/The-Transitional-Reinsurance-Program/Downloads/Transitional-Reinsurance-Documentation-Job-Aid-10-21-14.xlsm. This is an Excel file, in which an employer can input the required data and then save it as a CSV file (probably on your desktop for easy access) to upload at Pay.gov. Employers are not required to use this form, but the data must be submitted in this format.
File name: CMS recommends that the CSV file name be in the following format: [Legal business name of entity]_2014_[today’s date, e.g., 11122014]
Once you have this file completed, click the box to add the Supporting Documentation. Browse and attach the form, and the name of the attached document will show. This document must be in the CSV format that meets specific file layout requirements.
Some additional notes if you use the Job Aid file:
- Complete the blue-shaded cells on the Excel form. The green-shaded cells will populate based on the information input in the blue-shaded cells.
- Type of payment will be either “two-part collection” or “combined”
- Column M is 2014.
- Column N is the enrollment count, and need not be a whole number. It can be in the form NNNN.NN (that is, two digits to the right of the decimal point).
- Column O will be SI (“self-insured”) for employers who sponsor self-insured plans.
- It helps to run the data validation feature before saving the file as a CSV file, since this will only run in Excel, not once the file is saved as a CSV file.
- Save the CSV file on your computer or server so you can look at it before submitting it and also in case you need to correct or re-submit later. To review the file once you save it, CMS recommends opening it in Notepad. Opening it in Excel will automatically remove leading zeros and not replace them when you re-save it as a CSV file. If you open the file in Notepad, it will look like a string of characters, with no spaces between words.
Once you have an accurate CSV file, the steps to attach it (as noted above) are: Click the box to add the Supporting Documentation. Browse and attach the form, and the name of the attached document will show.
4- Enter Payment Information
Employers must select type of payment (First Collection, Second Collection or Combined Collection), specify a payment date, and submit banking information.
Note that the default payment date is the following day, so most employers will want to change the First Collection or Combined payment date to January 12, 13, 14 or 15, 2015, and change the Second Collection date to November 12th – 15th, 2015.
Important Note: The payment date must be at least 30 days after submission of the enrollee count to allow for submission count corrections, if necessary.
After selecting the payment date, plan sponsors must submit banking information, including the account holder name, type of account (checking or savings), the bank routing number and bank account number. In the account holder name, do not use special characters such as “&” or “!” as these will result in your submission not being accepted.
For an email confirmation, check “I would like to receive an email confirmation.” You can list others to receive an email confirmation also. You can print a receipt if you want or view the submission on the “My Forms” page.
You must click “I agree to the Pay.gov authorization and disclosure statement” and hit “Submit Payment.”
As noted above: If you only select First Collection, you must also go back and select Second Collection right after you submit the payment. The system will require it or will send you a follow-up email if you don’t (the email may go to your spam inbox). Both payments must be scheduled by December 5, 2014, even though the Second Collection is not due until November 15, 2015. You will submit the same CSV file with the Second Collection submission as you did with the First Collection submission. For the Second Collection you must schedule the Payment Date before November 15, 2015.
Important Note: CMS says that an Employer must give the Debit Blocker Code to its bank at least two weeks before the scheduled payment date. The Debit Blocker Code for the US Government is 7505008015.
For additional information:
- Documentation Job Aid Template, at http://www.cms.gov/CCIIO/Programs-and-Initiatives/Premium-Stabilization-Programs/The-Transitional-Reinsurance-Program/Downloads/Transitional-Reinsurance-Documentation-Job-Aid-10-21-14.xlsm
- “Supporting Documentation File Layout Requirements” at http://www.cms.gov/CCIIO/Programs-and-Initiatives/Premium-Stabilization-Programs/The-Transitional-Reinsurance-Program/Downloads/Supporting-Documentation-File-Layout-Requirements.pdf. (3-page explanation of required information)
- For details on the Oct. 29, 2014 CMS release, go to the REGTAP site at https://www.regtap.info/dashboard.php and search for FAQ “6438.” To search for the FAQ you will be required to enter your log-in information first.
- For additional background information on the Transitional Reinsurance Fee, see the May 2014 HealthReformUpdates.com article at https://news.leavitt.com/health-care-reform/cms-guidance-group-health-plans-will-pay-reinsurance-fees/ and January 2014 article at http://news.leavitt.com/health-care-reform/transitional-reinsurance-fees-january-2014-update/ .
- There is an instruction manual on the Pay.gov website that can be found at: http://www.cms.gov/CCIIO/Programs-and-Initiatives/Premium-Stabilization-Programs/The-Transitional-Reinsurance-Program/Downloads/RIC_FormManual_102014_v1.pdf