H&W: Reinsurance Fee Highlights

The Reinsurance Program Fee compliance activity (for self-insured plans) and reference material on Compliancedashboard provide information and reminders about this new ACA requirement. Listed below are several highlights that employers should keep in mind.

• This is a requirement for employer sponsors of self-insured major medical coverage. Insurers are responsible for reporting and fee payments related to fully insured plans.

• The number of covered lives with major medical coverage must be reported by November 15, 2014 via the www.pay.gov web site.

• Self-insured group health plans may utilize a third-party administrator or administrative-services-only contractor to report covered lives and pay the fee.

• Employers are given multiple options for counting covered lives, but must consistently use the same counting method throughout the counting period. They do not, however, have to use the same counting method from year to year.

• Most counting methods (except the Form 5500 counting method) look at the first nine months of the 2014 calendar year, regardless of the plan year.

• The counting method used to calculate the Reinsurance Program Fee does not need to match the method used to calculate the Patient Centered Outcomes Research Institute (PCORI) fee.

• Employers may choose one of two fee payment methods when they report their covered lives:
  • One Payment:
    • $63.00 per covered life due no later than January 15, 2015

    o   Two Payments

    • $52.50 per covered life due no later than January 15, 2015
    • $10.50 per covered life due no later than November 15, 2015