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The Center for Consumer Information & Insurance Oversight
The Transitional Reinsurance Program - Reinsurance Contributions
Alert: Annual Enrollment and Contributions Submission Form Filing Extension - December 5, 2014

Overview
Section 1341 of the Affordable Care Act established a transitional reinsurance program to stabilize premiums in the individual market inside and outside of the Marketplaces.  The transitional reinsurance program will collect contributions from contributing entities to fund reinsurance payments to issuers of non-grandfathered reinsurance-eligible individual market plans, the administrative costs of operating the reinsurance program, and the General Fund of the U.S. Treasury for the 2014, 2015 and 2016 benefit years.  

Who Makes Contributions?
Health insurance issuers and certain self-insured group health plans offering major medical coverage that is part of a commercial book of business are contributing entities.  For the purpose of reinsurance contributions, “major medical coverage” is defined in 45 CFR 153.20 as a catastrophic plan, an individual or a small group market plan subject to the actuarial value requirements under 45 CFR 156.140, or health coverage for a broad range of services and treatments provided in various settings that provides minimum value as defined in 45 CFR 156.145. A contributing entity must make reinsurance contributions on behalf of its enrollees in plans that provide “major medical coverage,” as defined under 45 CFR 153.20, unless one of the exceptions provided under 45 CFR 153.400 applies to such coverage.


Although a contributing entity is responsible for the reinsurance contributions, it may elect to use a third party administrator or administrative services-only contractor for submission of enrollment data and the transfer of the reinsurance contributions.

How Does a Contributing Entity Make Reinsurance Contributions?
HHS is implementing a streamlined approach to complete the contributions process through Pay.gov.  To successfully complete the reinsurance contribution process, contributing entities, or third party administrators or administrative services-only contractors on their behalf, must register on Pay.gov.


Using Pay.gov, the contributing entity (or third party administrators or administrative services-only contractors on their behalf) will access the “ACA Transitional Reinsurance Program Annual Enrollment and Contributions Submission Form” to enter the annual enrollment count. The ACA Transitional Reinsurance Program Annual Enrollment and Contributions Submission Form will auto-calculate the annual contribution amount to be remitted based on the annual enrollment count and the contributing entity will then schedule payment for the calculated reinsurance contributions on the payment page.

 

Key Reinsurance Contribution Deadlines for the 2014 Benefit Year

 Date  Activity  Contribution Amount
 October 24, 2014  ACA Transitional Reinsurance Program Annual Enrollment and Contributions Submission Form Available on Pay.gov  
 Extended until 11:59pm on December 5, 2014 Contributing Entities Submit Annual Enrollment Count  
 No later than
January 15, 2015
 Contributing Entities Remit First Contribution Amount (or Combined Contribution Amount)  $52.50 per covered life (if remitting first contribution amount)
or
$63.00 per covered life (if remitting combined contribution amount)
No later than
November 15, 2015
Contributing Entities Remit Second Contribution Amount $10.50 per covered life
(if remitting second contribution amount)
    
  TOTAL $63.00 per covered life

 

We note that HHS will offer contributing entities the option to pay: (1) the entire 2014 benefit year contribution in one payment no later than January 15, 2015 reflecting $63.00 per covered life; or (2) in two separate payments for the 2014 benefit year, with the first remittance due by January 15, 2015 reflecting $52.50 per covered life, and the second remittance due by November 15, 2015 reflecting $10.50 per covered life.  

Announcements
Annual Enrollment and Contributions Submission Form Filing Extension - December 5, 2014
We have received requests for an extension of the deadline for contributing entities to submit their 2014 enrollment counts for the transitional reinsurance program contributions under 45 CFR 153.405(b).  The deadline has now been extended until 11:59 p.m. on December 5, 2014.  The January 15, 2015 and November 15, 2015 payment deadlines remain the same.

Transitional Reinsurance Program Annual Enrollment and Contributions Submission Form Availability
The ACA Transitional Reinsurance Program Annual Enrollment and Contributions Submission Form will be available via www.pay.gov on Friday, October 24, 2014 in time for the 2014 benefit year’s annual enrollment submission deadline of November 15, 2014.


Upcoming Webinars Pertaining to the Reinsurance Contributions Submission Process

Please visit REGTAP via https://www.REGTAP.info for upcoming educational opportunities related to the reinsurance program.