Late Payment of the Transitional Reinsurance Fee

 November 23 2015     David Anthony

Recently, the 2015 Transitional Reinsurance Fee had its annual requirement for self-funded plans to submit information on their annual enrollment and schedule a payment of the Transitional Reinsurance Fee no later than November 16, 2015. In 2014 the fee per covered life was $63 and in 2015 the fee is $44 per covered life. Self-funded plan sponsors are required to report covered lives and make a fee payment on behalf of the plan.

What if your health plan has failed to pay or sign up for this year’s payment? If your health plan failed to schedule a payment or did not make the 2014 payment, your health plan may be subject to a late penalty. Non-payment of the Transitional Reinsurance Fee is considered a federal debt and subject to federal debt collection rules as well as interest and penalties.

Centers for Medicare and Medicaid Services (CMS) have encouraged health plans that have not filed in previous years to access the 2014 Transitional Reinsurance Fee Form on the CMS website and remit a payment, or contact CMS directly via email at for previous forms or questions regarding the payment process.

The information contained in this document is informational only and is not intended as, nor should it be construed as, legal or accounting advice. Neither HORAN nor its consultants provide legal, tax nor accounting advice of any kind. We make no legal representation nor do we take legal responsibility of any kind regarding regulatory compliance. Please consult your counsel for a definitive interpretation of current statute and regulation and their impact on you and your organization. Thank you.