Reminder to Pay Transitional Reinsurance Program Fees

By Bruce Davis

If you paid the 2015 Transitional Reinsurance Fee of $44 per member (applies to both employee and covered dependents) in installments, the 2nd installment of $11 per member is due November 15, 2016.

The 2016 Reinsurance fee of $27, if paid in one lump sum, is due by January 17, 2017.  Groups have to report the total members in their plan by November  15, 2016.

If you plan to pay the 2016 Reinsurance Fee in two installments, the 1st installment of $21.60 per member is due January 17, 2017.  However, if you are a self-funded employer, you would still need to report to HHS by November 15, 2016 the number of covered lives.  The 2nd installment of $5.40 per member would then be due November 15, 2017.

These fees can be paid using www.pay.gov.

Although most employers are using the Snapshot method in determining the average number of covered lives, there are other approved methods available to self-funded employers.

2016 is the last year to which Transitional Reinsurance Fees apply.  However, given the shortfalls in the ACA risk corridor program that have prompted several Blue Cross Blue Shield plans and insurers to sue the federal government for payment, it’s possible the government will be looking for revenue sources to not only settle with insurers, but also to stabilize premiums in the Healthcare.gov public exchange. Employers will need to stay alert for how this may directly impact them.

If you have questions about this process, please call your Findley Davies consultant or Bruce Davis.

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