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April 17, 2015

HRB 108: Transitional Reinsurance Fee Refund Requests (article)

HRB 108:  Transitional Reinsurance Fee Refund Requests
Released April 17, 2015 I Download as a PDF

The CMS’ Center for Consumer Information and Insurance Oversight (CCIIO) has provided guidance on obtaining a refund if the transitional reinsurance fee was calculated improperly.   

As background, the Affordable Care Act (ACA) imposes a transitional reinsurance fee, the goal of which is to help stabilize premiums in the individual market due to enrollment of higher risk individuals in the marketplace. All insurers and plan sponsors of self-funded plans (“contributing entities”) are required to contribute to this reinsurance fund over a three year period from 2014 through 2016.

 

For the 2014 benefit year, contributing entities were required to submit their annual enrollment count and schedule their resulting contributions on a self-reporting form via www.pay.gov by December 5, 2014. The reporting form auto-calculated the annual contribution amount based on the enrollment count submitted by the contributing entity.  The contribution amount of $63 per covered life was due on January 15, 2015.  Or, if the entity elected to pay the fee in two installments, the first contribution amount of $52.50 per covered life was due on January 15, 2015; the second contribution amount of $10.50 per covered life is due November 15, 2015.  (For the 2015 benefit year, the annual reinsurance contribution rate to be collected is $44 per covered life; further reducing to $27 per covered life in 2016.  For self-reporting purposes for the 2015 and 2016 benefit years, presumably the reports will be due by November 15th of the respective reporting year.)

 

If a contributing entity discovers an error in its annual enrollment count submitted on the 2014 reporting form, it can request a refund from CMS.  The refund request must be accomplished by April 30, 2015, or 90 days from the date the entity submitted its form, whichever is later. For the 2015 and 2016 benefit years, refund requests based on enrollment count errors must be submitted within 90 days of the date the form was submitted.

 

Refund requests and other inquiries relating to the transition reinsurance contribution process should be sent to reinsurancecontributions@cms.hhs.gov.

 

 The information contained herein is not intended to be legal, accounting, or other professional advice, nor are these comments directed to specific situations. The information contained herein is provided as general guidance and may be affected by changes in law or regulation. The information contained herein is not intended to replace or substitute for accounting or other professional advice. Attorneys or tax advisors must be consulted for assistance in specific situations. This information is provided as-is, with no warranties of any kind. CBIZ shall not be liable for any damages whatsoever in connection with its use and assumes no obligation to inform the reader of any changes in laws or other factors that could affect the information contained herein.

 

 

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