Transitional Reinsurance Fee Program Assistance Reminder
September will be here before we know it. We’d like to remind you that if you had opted into Meritain Health’s Transitional Reinsurance Program last year, you will need to opt in for 2016 if you’d like to continue receiving this enhanced service. This service is also available to groups who did not opt in last year, but wish to do so for the final year. The deadline to opt in is September 1, 2016.
What is the amount of the reinsurance fee that plans can expect to pay in 2016?
For 2016, the government will assess the Reinsurance Contribution (RC) fee at $2.25 monthly per covered life, or $27 annually per covered life, based on the average number of lives covered under a plan during the first nine calendar months of the year. The annual payment can be submitted in full or in two installments: $21.60 in January 2017 and $5.40 late in the fourth quarter of 2017.
When and to whom must a plan report their covered lives in 2016?
Each self-funded group health plan is responsible for reporting its covered life count to the Department of Health and Human Services (HHS) using the website www.Pay.gov and by completing the Transitional Reinsurance Form by November 15, 2016. HHS will determine the amount of the fee, and groups can determine the date they will issue payment, provided that payment is made prior to January 15, 2017.
What reporting method will Meritain Health support?
Meritain Health will be able to provide a report to support our self-funded customers requesting RC calculations. This report will be available at no charge and will enable plans, as well as authorized consultants and brokers, to access plan membership information. Meritain Health will have two reporting options available—the snapshot count method and the snapshot factor method—so plans may choose the best option based on their employee enrollment. The available reports will apply for memberships administered by Meritain Health only.
What enhanced services are available to assist with remitting this fee to the government?
At this time, Meritain Health is prepared to offer two enhanced options to our clients to help assist with this reporting requirement:
1. Periodically. Meritain Health will calculate enrollment based on a snapshot of the first three quarters of the calendar year and bill in three periodic installments, no later than the first day of April, July and October of the same calendar year. Payment to Meritain Health is due by the first of the month for the billing invoice date, with no exceptions. Meritain Health will then remit the total fee on your behalf at the end of the year.
2. Yearly. Meritain Health will calculate enrollment based on a snapshot of the first three quarters of the calendar year and bill in October. Payment to Meritain Health is due by the first of the month for the billing invoice date, with no exceptions. Meritain Health will remit the fee on your behalf to HHS at the end of the year.
If you have any questions, please contact your Client Solutions team.
Compliance Corner is being provided as an informational tool. It is recommended that plans consult with their own experts or counsel to review all applicable federal and state legal requirements that may apply to their group health plan. By providing this publication and any attachments, Meritain Health is not exercising discretionary authority over the plan and is not assuming a plan fiduciary role, nor is Meritain Health providing legal advice.