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Nov 2014
06
November 06, 2014

Group Health Plans Must Report Number of Individuals Covered by Nov. 17


A new filing deadline for reporting the number of individuals enrolled in your health plan is rapidly approaching. By Nov. 17, 2014, 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, which HHS will use 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. If you are an employer that sponsors a self-insured plan, you should check with your third-party administrator to determine whether it will be reporting on your 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 2014 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 employees covered under the plan on the same day of each quarter, but for each day multiply the number of employees with dependent coverage by a factor of 2.35 before calculating the average; or
  • 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.
Once you have submitted the counts, the Pay.gov website will automatically calculate the contribution amount (for 2014, this is based on $63 per covered life). You can then decide whether to make one payment (due Jan. 15, 2015) or two installment payments ($52.50 per covered life, due Jan. 15, 2015; and $10.50 per covered life, due Nov. 15, 2015).

If you have questions regarding which method to use for purposes of your enrollment count, please contact Norbert Kugele (616.752.2186 or nkugele@wnj.com), April Goff (616.752.2154 or agoff@wnj.com), Amy Fredrickson (248.784.5059 or afredrickson@wnj.com), or any other member of the Warner Norcross & Judd LLP Employee Benefits / Executive Compensation Practice Group.

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