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Transitional Reinsurance Program: Deadlines Approaching November 15th

 October 20 2016     Diane Cross
As a reminder, on November 15, 2016, the Affordable Care Act (ACA) Transitional Reinsurance Program (TRP) 2016 Annual Enrollment and Contributions Submission Form is due, along with the second payment of the 2015 Transitional Reinsurance Contribution if making payment in two installments.

The TRP is a temporary program designed to stabilize premiums in the individual health insurance market as part of implementing the ACA. The TRP requires any health plan providing major medical coverage to contribute a fee for each covered life (employees and dependents) that the health plan covers. Note that excepted benefits including standalone dental and vision plans, flexible spending accounts, health reimbursement arrangements, health savings accounts and other limited plans are not required to make a TRP fee payment.

For fully-insured plans, the fee will be paid by the insurer and is included in the premium. Self-funded plan sponsors (generally, the employer) will be required to report covered lives and make a fee payment on behalf of the plan. A third party administrator may assist with the calculation and pay the applicable fee on behalf of the plan sponsor.

Payment can be paid one of two ways, either as a lump sum or in two installment payments. If a lump sum contribution applicable to 2015 was paid in January, only the 2016 Annual Enrollment and Contributions Submission Form is due by November 15th. If payment was made for 2015 in two installments, both the second installment payment for 2015 and the 2016 Annual Enrollment and Contributions Submission Form are due.

If making a lump sum payment for 2016, the full payment of $27 per covered life is due by January 17, 2017. If making payment via two installments for 2016, the first installment of $21.60 is due January 17th and the second payment of $5.40 per covered life is due November 15, 2017.

The TRP Annual Enrollment and Contributions Submission Form is available and payments should be submitted through https://www.pay.gov/.

HORAN can assist employers by helping gather the necessary information to calculate covered lives for the annual enrollment report. For most employers, the easiest count to calculate or provide is either the 5500 count from annual Form 5500 filings of ERISA plans or the snapshot count method. At your request, we will contact your administrator for information for the snapshot count calculation or provide the calculation from your annual Form 5500 filing if applicable.

Important 2017 dates to note:
January 17, 2017 – Lump sum payment due of $27 per covered life (or first installment of $21.60 per covered life if paying in two installments)
November 15, 2017 – Second installment due ($5.40 per covered life)

For more information, visit:
https://www.cms.gov/CCIIO/Programs-and-Initiatives/Premium-Stabilization-Programs/The-Transitional-Reinsurance-Program/2016-Benefit-Year-Page.html

Please contact your HORAN representative with any questions.