Health Care Reform, Reinsurance Fee, Transitional Reinsurance Fee

2015 Transitional Reinsurance Fee—Forms Now Available Online

(Updated October 19, 2015 to note a change from 2014 filing: no supporting documentation needed if filing for fewer than 4 contributing entities.)

New announcement on the CCIIO website: The ‘2015 ACA Transitional Reinsurance Program Annual Enrollment and Contributions Submission Form’ (2015 Form) is Now Available at https://www.pay.gov/public/form/start/70746962.  (Also at www.pay.gov, search for “2015 ACA Transitional Reinsurance” to access the 2015 form.)

Monday, November 16, 2015: Deadline by which contributing entities must submit the 2015 Form and schedule reinsurance contribution payment(s). Payment for 2015 is $44 per enrollee (per “covered life” – which includes employees and dependents). The payment may be made in one installment due by January 15, 2016, or in two installments with the first one of $33 per enrollee made by January 15, 2016 and the second installment of $11 per enrollee by November 15, 2016.  The reinsurance fees amount is calculated based on the plan’s enrollment count during the first nine calendar months of the year, regardless of the plan’s actual plan year.

Contributing Entities who must pay the Transitional Reinsurance fee are:

  • Health insurance issuers, and
  • Self-insured group health plans that do not self-administer claims

Contributing entities are responsible for the reinsurance contributions, but they may elect to use third party administrators or administrative services-only contractors submit the enrollment data and to transfer the reinsurance contributions.

Note a good change from last year:  You need NOT file supporting documentation (the .CSV file) if you are reporting for fewer than 4 contributing entities!  Many employers had problems last year correctly completing and uploading the .CSV file.

Plans Subject to the Transitional Reinsurance Fee

A contributing entity must make reinsurance contributions on behalf of its enrollees in plans that provide “major medical coverage,” as defined under 45 CFR 153.20, unless one of the exceptions provided under 45 CFR 153.400 applies to such coverage.

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 Transitional Reinsurance Program Fee (reinsurance fee) applied as of January 1, 2014 to both insured and self-funded “major medical” plans. The fee applies as of January 1 regardless of the plan year or policy year.

How Does a Contributing Entity Make Reinsurance Contributions?

  1. Contributing entities, or third party administrators or administrative services-only contractors on their behalf, must register on Pay.gov.  Any contributing entity or third party administrators or administrative services-only contractor who created a Pay.gov account for the 2014 benefit year can use this account for the 2015 benefit year.
  2. Using Pay.gov, access the “2015 ACA Transitional Reinsurance Program Annual Enrollment and Contributions Submission Form” to enter the annual enrollment count for the 2015 benefit year.  Please note that there is a specific Form for each benefit year.
  3. The Form will auto-calculate the annual contribution amount to be remitted, based on the annual enrollment count during the first nine calendar months of the year.
  4. The contributing entity will then schedule payment for the calculated reinsurance contributions on the payment page.

New Web-Based Training from CCIIO:  For more information on completing the 2015 Form or the 2015 Supporting Documentation, use the 2015 Reinsurance Contributions Form Completion and Submission Web-Based Training (WBT). This WBT is readily available to walk users through the process to create the 2015 Supporting Documentation and complete the 2015 Form.  This Web-Based Training is available at: https://www.regtap.info/ricontributions.php.

What are the Key Program Dates?

Key Reinsurance Contribution Deadlines for the 2015 Benefit Year
Date Activity Contribution Amount
1-Oct-15 2015 ACA Transitional Reinsurance Program Annual Enrollment and Contributions Submission Form Available on Pay.gov
To Make a Full Contribution in One Payment (Combined Collection):
No later thanNovember 16, 2015 Submit the Form and schedule payment by due date
No later than January 15, 2016 Full contribution amount due (single payment) $44.00 per covered life
TOTAL $44.00 per covered file
OR
To Make a Two-part Contribution (First and Second Collection):
No later thanNovember 16, 2015 Submit the Form and schedule payment of first collection contribution (by due date) and duplicate the Form and schedule payment of second collection(by due date)
No later thanJanuary 15, 2016 First contribution amount due $33.00 per covered life
No later thanNovember 15, 2016 Second contribution amount due $11.00 per covered life
TOTAL $44.00

 Reinsurance Contribution Submission Hotline

CMS will hold a hotline to assist contributing entities in completing the 2015 ACA Transitional Reinsurance Program Annual Enrollment and Contributions Submission Form, this hotline will be an open during the dates and times specified below.  All entities dialed into the hotline can benefit from questions asked and answered.  In addition, CMS will respond to questions sent to ReinsuranceContributions@cms.hhs.gov.

    • Monday, 10/26/15 – 1:00pm – 2:30 pm EST
    • Wednesday, 10/28/15 – 1:00pm – 2:30 pm EST
    • Wednesday, 11/4/15 – 1:00pm – 2:30 pm EST
    • Thursday, 11/5/15 – 1:00pm – 2:30 pm EST
    • Monday, 11/9/15 – 8:00am – 6:00pm EST
    • Tuesday, 11/10/15 – 8:00am – 6:00pm EST
    • Wednesday, 11/11/15 – 8:00am – 6:00pm EST
    • Thursday, 11/12/15 – 8:00am – 6:00pm EST
    • Friday, 11/13/15 – 8:00am – 6:00pm EST
    • Monday, 11/16/15 – 8:00am – 6:00pm EST

Reminder:  All contributing entities must submit the 2015 Form and schedule reinsurance contribution payment(s) no later than Monday, November 16, 2015.

Additional Resources 

Go to the bottom of the page at https://www.cms.gov/CCIIO/Programs-and-Initiatives/Premium-Stabilization-Programs/The-Transitional-Reinsurance-Program/Reinsurance-Contributions.html