Transitional Reinsurance Fee Deadline Approaching

The deadline is Monday, November 16, 2015. Your self-funded health plan must submit your enrollment count and schedule your payments for the 2015 plan year. Are you prepared?
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 was $63 per person. The 2015 fee is $44 per person, which the updated regulation proposes to collect in two installments: $33.00 in January 2016, and $11.00 late in the fourth quarter of 2016. (Reports due 11/16/2015, HHS’ bill comes 12/15/2015, bills due in installments; typically from your ASO-claims payer to HHS). For 2016, the proposed fee is $27 per person.
HHS has not yet updated their Annual Enrollment and Contributions Submission Form Manual (64 pages) and a Supporting Documentation Job Aid Manual (14 pages), but they did do a series of webinars and they offer 3 Modules of “assistance” related to questions and issues that the dealt with during last year’s submissions and payments.
In light of the fact that the November 15th deadline is a Sunday in 2015, HHS states (in an FAQ) that self-funded plans (aka contributing entities) may submit their enrollment count by Monday, November 16th this year. It is advisable not to wait that long because Pay.gov may experience bottleneck-issues as the deadline approaches.
HHS/CMS uses the annual enrollment count to calculate an entity’s contribution amount due for the applicable year. Plan sponsors have a choice of four counting methods. They may use different counting methods for their various plans and may also use a different counting method than that used for 2014.
The counting methods are the same as last year:
Actual count.
Snapshot count.
Snapshot factor.
Form 5500.
Under all alternatives except the Form 5500 method, the number of covered lives for 2015 will be determined based on the first nine months of the 2015 calendar year. This is a calendar year fee (tax) on all self-funded plans.