Health Care Reform, Reinsurance Fee, Taxes, Fees & Penalties

Final Reinsurance Fee Due by November 15th!

By November 15, the second portion of the 2016 transitional reinsurance fee (TRF) is due.  Employers who sponsor  self-funded health plans were required to submit 2016 enrollment data to Pay.gov last year and could have scheduled the full payment for January 16, 2017, or could have paid only the first payment ($21.60 per enrollee) as of January 16th and scheduled the second portion ($5.40 per enrollee) to be paid by November 15th, 2017.  Payments must be made using an Automatic Clearing House (AHC) debit on Pay.gov.

If you owed a 2016 TRF elected to pay it in two payments, now is the time to remove the AHC Debit Block to ensure your bank does not block the AHC debit. To do this, add Agency Location Code (ALC+2 value) 7505008016 (USDEPTHHSCMS) to your list of approved companies for AHC automatic debits, or make sure this is already on your list.

Also, make sure there are sufficient funds in your account to pay the TRF.

The TRF was in effect from 2014-2016, so there is no 2017 TRF to schedule this November. Total TRF for 2016 was $27 per enrollee. For transitional reinsurance payments for 2016, see https://www.cms.gov/CCIIO/Programs-and-Initiatives/Premium-Stabilization-Programs/The-Transitional-Reinsurance-Program/2016-Benefit-Year-Page.html

Background on the Transitional Reinsurance Fee

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 was 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. As noted above, the payments in 2017 (for the 2016 benefit year) were the last reinsurance payments.

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