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Nov 2016
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November 10, 2016

ACA Reinsurance Fee Filing Due November 15


The filing deadline for reporting the number of individuals enrolled in your health plan is rapidly approaching. By November 15, 2016, group health plans must report to the Department of Health and Human Services (HHS), using the Pay.gov website, the number of lives covered under the plan. HHS will use that number to calculate payments due for the temporary reinsurance program.

For fully-insured health plans, the insurer is responsible for submitting the report. For self-insured health plans, the “plan” is required to submit the information, though a third-party administrator may report on the plan’s behalf. Even if your third-party administrator is submitting the information, it may ask you to determine the number of lives to be reported. Please note that for this purpose, a “covered life” is not the relevant number of your employees, but the total number of individuals (including dependents) covered under your plan.

Self-insured plans must determine the number of covered lives over the first nine months of 2016 using one of four different methods:
  • Average the number of lives covered under the plan each day during the first nine months of the year;
  • Take a “snapshot” count of the number of covered lives on approximately the same day (or the same multiple days) of each quarter and average those snapshot counts;
  • Take a “snapshot” count of covered employees on the same day of each quarter using a “factor” to estimate the total number of lives, and then average these factored snapshot counts. Under this method, on each of the selected days, you first count the number of employees with self-only coverage and then add the number of employees with dependent coverage multiplied by a factor of 2.35; 
  • Using the most recently filed 5500 form, add the number of participants covered at the beginning of the year and at the end of the year (and if you only offer self-only coverage, then divide this number by 2).
Group health plans must use the same method for the entire 2016 period. However, group health plans are not required to use the same method as they used in prior years.

To submit the count, visit Pay.gov and search for “2016 ACA Transitional Reinsurance Program Annual Enrollment Contributions” to complete the required form. Once you have submitted the counts, the Pay.gov website will automatically calculate the contribution amount (for 2016, this is based on $27 per covered life). You can then decide whether to make one payment (due January 17, 2017) or two installment payments ($21.60 per covered life, due January 17, 2017; and $5.40 per covered life, due November 15, 2017).

If you have questions regarding which method to use for purposes of your enrollment count, please contact Norbert Kugele, Kent Sparks or any member of the Warner Norcross & Judd LLP Employee Benefits / Executive Compensation Practice Group.

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