Special Alert: Deadline Delayed to Submit ACA Reinsurance Program Enrollment Counts

Employers Subject to ACA Transitional Reinsurance Program Now Have Until December 5, 2014 to Submit Annual Enrollment Counts

balance-scaleThe U.S. Centers for Medicare & Medicaid Services (CMS) has announced that the deadline for employers sponsoring certain self-insured plans (“contributing entities”) to submit their 2014 enrollment counts for transitional reinsurance program contributions has been extended until 11:59 p.m. on December 5, 2014. (The previous deadline was November 15, 2014.)

Contributing Entities

Health insurers and certain self-insured group health plans offering “major medical coverage” that is part of a commercial book of business are generally required to make reinsurance contributions on behalf of the entity’s enrollees. Among other types of coverage, contributing entities are generally not required to make contributions on behalf of:

  • Self-insured group health plans or health insurance coverage that consists solely of excepted benefits;
  • Health reimbursement arrangements (HRAs) that are integrated with self-insured group health plans or health insurance coverage;
  • Health savings accounts (HSAs); or
  • Health flexible spending arrangements (health FSAs).

How Payments Are Made

To successfully complete the reinsurance contribution process, contributing entities (or third-party administrators or administrative services-only contractors on their behalf) must register on www.pay.gov and submit their annual enrollment count of the number of covered lives of reinsurance contribution enrollees for the applicable benefit year.

After contributing entities complete the ACA Transitional Reinsurance Program Annual Enrollment and Contributions Submission Form, their annual contribution amounts to be remitted will be auto-calculated. Contributing entities will then enter their payment information and will be given a chance to review and submit the calculated reinsurance contributions. The payment deadlines for the 2014 benefit year (January 15, 2015 and November 15, 2015) remain the same.

For More Information

Additional resources for completing the reinsurance contribution process, including user manuals, are available from CMS. You may also check out the Transitional Reinsurance Program section of your online HR library, which includes information regarding the tax treatment of contributions made under the program.

Please Note: The information and materials herein are provided for general information purposes only and are not intended to constitute legal or other advice or opinions on any specific matters and are not intended to replace the advice of a qualified attorney, plan provider or other professional advisor. This information has been taken from sources which we believe to be reliable, but there is no guarantee as to its accuracy. In accordance with IRS Circular 230, this communication is not intended or written to be used, and cannot be used as or considered a ‘covered opinion’ or other written tax advice and should not be relied upon for any purpose other than its intended purpose.

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