The Centers for Medicare and Medicaid Services announced an April 30 deadline for claiming certain overpayments of the transitional reinsurance fee.
The announcement covers overpayments due to miscalculating enrollment counts on which the fee is based. Such miscalculations occur for two reasons, CMS said:
- misapplication of a permitted method for determining the annual enrollment count; or
- including individuals in the count for whom the fee was not required.
In cases where the fee has been paid, employers and insurers must refile their forms with correct enrollment counts and request a refund from CMS. Where the fee has not been paid yet, they can merely refile through www.pay.gov.
The fee exists to stabilize premiums in the individual market. For the 2014 benefit year, employers with self-funded health plans and insurers for fully insured group plans had to submit: (1) enrollment counts on Dec. 5, 2014; (2) full or main (if they chose to pay in two installments) payments on Jan. 15, 2015; and (3) second remittances no later than Nov. 15, 2015. The contribution rate per covered life is $63 for the 2014 benefit year.
For the 2015 and 2016 benefit years, refund requests are due 90 days from the date of their form submission.
Employers with self-insured plans that paid the TRF for 2014 may wish to review the enrollment counts reported if they have concerns that they may have overpaid.
Refund requests and other inquiries about the reinsurance contribution submission process should be sent to reinsurancecontributions@cms.hhs.gov.
For more information about the transitional reinsurance fee, go to ¶795 of the New Health Care Reform Law: What Employers Need to Know.