Self-Funded Plans Must File Transitional Reinsurance Program Form By December 5
The transitional reinsurance fee (TRF) applies to fully insured and self-funded major medical plans for 2014, 2015, and 2016. The purpose of the fee is to provide funds to help stabilize premiums in the individual insurance market in view of uncertainty about how the Patient Protection and Affordable Care Act (PPACA) would affect claims experience. Insurers are responsible for reporting and paying the fee on the policies they issue, although the fee will generally be passed on to the employer. Plan sponsors of self-funded plans (or their representatives) must report and pay the fee to the federal government at www.pay.gov.
All plans that provide primary major medical coverage to employees or retirees owe this fee. Major medical coverage includes medical plans that provide minimum value (that is, have an actuarial value of 60% or more) and all medical policies provided through the Marketplace.
The annual fee is $63.00 per covered life for 2014 ($5.25 per month). The fee is $44.00 per covered life for 2015. The fee is expected to be approximately $27.00 per covered life in 2016. The fee is based on covered lives (i.e., employees, retirees, and COBRA participants and covered spouses and children).
The methods available to count lives are very similar to those used to count lives for the Patient Centered Outcomes Research Institute (PCORI) fee. However, the TRF is calculated on a calendar year basis, and lives are only counted for the first nine months of the year to accommodate the November 15 filing date.
The TRF filing is due by December 5, 2014, November 15, 2015, and November 15, 2016. (The due date is the same for both calendar year and non-calendar year plans. The 2014 due date was extended from November 15, 2014, to December 5, 2014.) The fee is due the following January 15, although insurers and plan sponsors have the option to pay the fee in two unequal installments. If the 2014 fee is paid in installments, $52.50 per person will be due January 15, 2015, and $10.50 per person will be due November 15, 2015.
See our FAQ on this requirement for more information.