The ACA established a Transitional Reinsurance Program to help stabilize premiums for coverage in the individual market during the years 2014 through 2016. The statute requires all fully insured and self-insured group health plans to make contributions under this program to support payments to individual market issuers that cover high-cost individuals. Insurance carriers will send in payment of the fee on behalf of fully insured plans, however the regulations say that self-insured group health plans are liable for the fee.
For the 2015 benefit year, HHS will offer contributing entities the option to pay: (1) the entire 2015 benefit year contribution in one payment no later than January 15, 2016 reflecting $44.00 per covered life; or (2) in two separate payments for the 2015 benefit year, with the first remittance due by January 15, 2016 reflecting $33.00 per covered life, and the second remittance due by November 15, 2016 reflecting $11.00 per covered life.
For the 2014 benefit year, HHS offered contributing entities the option to pay: (1) the entire 2014 benefit year contribution in one payment no later than January 15, 2015 reflecting $63.00 per covered life; or (2) in two separate payments for the 2014 benefit year, with the first remittance due by January 15, 2015 reflecting $52.50 per covered life, and the second remittance due by November 15, 2015 reflecting $10.50 per covered life.
The membership counting methods provided for self-funded employers are the same as those which are available for calculation of the PCORI fee, however the time period used is based on the calendar year (instead of plan year like for the PCORI fee). The Reinsurance Fee is a temporary program which is planned to decline for three years and then be eliminated.