The Centers for Medicare & Medicaid Services has extended the deadline for contributing entities (or entities reporting on their behalf) to submit annual enrollment counts on which they will base their contribution amounts under health care reform’s transitional reinsurance program.
The deadline is now 11:59 p.m. on Dec. 5, 2014. Reporting on that date also includes whether contributing entities will choose either a combined or two-part contribution, CMS announced.
Contributing entities reporting on their own behalf (or their third-party administrators or administrative-services-only contractors) will submit enrollment counts and schedule contributions, by registering on www.pay.gov. Detailed instructions are found here (registration required). CMS published a 64-page manual to help insurers, TPAs and employers fill out their submissions.
The regulatory deadline was originally Nov. 15. The annual enrollment count and schedule deadline will revert to Nov. 15 for 2015 and 2016. Here is a link to the annual enrollment and contribution submission forms. More information about how to submit enrollment data is available here.
Other dates — including the first required payment of $52.50 per covered life per year on Jan. 15, 2015 and the second contribution of $10.50 per covered life per year on Nov. 15, 2015 — remain unchanged.
Background
The transitional reinsurance program was set up to stabilize premiums in the individual market, as part of health care reform. It will collect $63 per year per covered life from health insurers and self-insured group health plans to fund reinsurance payments to companies that issue health insurance policies for the 2014 benefit year. A lower $44 amount has been announced for 2015; the amount for 2016 has not yet been announced. The fund also covers the administrative costs of operating the program and contributes to the U.S. Treasury. The program sunsets after 2016, so the fee will not be collected for 2017 and thereafter.
Details
Health insurers and self-insured group health plans that sponsor major medical coverage must contribute to the fund. “Major medical coverage” is defined in 45 C.F.R. 153.20 as a catastrophic plan, an individual or a small group market plan subject to health care reform’s actuarial value requirements.
Reporting entities are organizations that carry out the steps for the reinsurance contribution. They can be the contributing entity itself, or a TPA or ASO contractor acting on behalf of the contributing entity.
Although a contributing entity is responsible for the reinsurance contributions, it may elect to use a TPA or ASO contractor for submission of enrollment data and the transfer of the reinsurance contributions.
Two common errors plan sponsors need to look out for are: (1) incorrect gross annual enrollment counts on the form; and (2) gross annual enrollment counts that do not match the sum of the annual enrollment counts in the supporting documentation. If the form reflects a lower gross annual enrollment count than the supporting documentation, CMS will issue an invoice for the outstanding amount.
Supporting documentation includes the reporting entity’s name, tax ID, address, etc., as well as information on the type of contributing entity. More background on this topic can be found in this article.
The Jan. 15, 2015 and Nov. 15, 2015 payment deadlines remain the same.