Washington State has a Partnership Access Line (PAL) consisting of four state-organized psychiatric referral programs operated by the University of Washington and Seattle Children’s Hospital.
In 2020, the legislature passed a law to create a fund (WAPAL fund) to support its PAL programs through a new assessment imposed on insurance carriers, employers that sponsor self-insured medical plans, and self-insured multiple employer welfare arrangements (hereinafter entities).
The assessment will not only apply to entities based in Washington, but to entities outside of the state that have any plan that insures or covers Washington residents. The assessment does not apply to account based plans such as HRAs or FSAs or dental or vision plans.
Assessed entities will log into the WAPAL fund website at the end of every calendar quarter to report the number of covered lives and receive an invoice for the quarterly assessment.
The number of covered lives reported must include any individual covered by the plan (insured or self-insured) that is a Washington resident (individuals residing outside of Washington state should be omitted). Covered lives include active employees, their covered dependents, COBRA qualified beneficiaries, and retirees.
The assessment for Q3 of 2021 will be 13 cents per covered life. This amount is due by November 15, 2021.
For fully-insured health plans, the carrier will be responsible for compliance with the PAL assessment. For self-insured health plans, the employer will be responsible for compliance with the PAL assessment. Employers sponsoring self-insured plans should coordinate with their TPAs to determine whether they will provide any assistance in handling the WAPAL Fund assessment.
Washington State Health Care Authority has available on its website additional information for assessed entities, FAQs, and other resources.
It is possible that self-funded plans subject to ERISA will challenge this surcharge.
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