Transition reinsurance form available on Pay.gov

Transition reinsurance form available on Pay.gov

Bulletin Type: 
Health Care Reform

Deadline for submission is November 15

Today, the long-awaited form self-insured plans sponsors need to submit the transition reinsurance fee, mandated by the Affordable Care Act, was posted on pay.gov. The deadline for submitting the completed form to the Centers for Medicare and Medicaid Services (CMS) is November 15, 2014.

CMS has developed a Microsoft Excel Job Aid that plan sponsors (Reporting Entities) should complete and submit with the form to substantiate the fee amount owed. The fee is based on covered lives, which includes covered employees, dependents and spouses. In 2014, (payable in 2015), the fee is $63 per covered life annually; in 2015 the annual fee is $44. The fee ends with the 2016 benefit year (payable in 2017). Plan sponsors are permitted to deduct fees as an ordinary and necessary business expense.

Information can be entered directly into the Job Aid. After entering the requested data, the Job Aid must be converted to a CSV file and uploaded to pay.gov. CMS has provided an instruction guide to assist with completion of the Job Aid, as well as an enrollment and submission manual that reviews the form submission process.

Banking

While the deadline for paying the fee is January 15, 2015, the payment arrangements are confirmed during the form submittal process. Payment must be scheduled and made through pay.gov. CMS recommends payment be made 30 days from the filing date, but no later than the January 15, 2015, deadline. The form requires bank information, such as routing and account number. The amount owed auto-populates based on enrollment data entered in the form. It’s important to notify your bank in advance of the ACH payment. The bank may require setup time to accommodate the payment. When working with the U.S. Government, the bank needs to know the Agency Location Code or the ALC+2 value. For the reinsurance contribution, the ALC+2 is 7505008015.

Please contact your Bukaty Companies benefits consultant for assistance.

Tips:

  • Determine the number of covered lives before you start the process. Covered lives can be determined by using any of the CMS recommended methods identified in an earlier Bukaty Benefit Bulletin. Important to note is that the count is based on the first nine months of the year (January 1 – September 30), whether the plan year a calendar year or a non-calendar year. 
  • The snapshot count method appears to be the easiest to calculate, but the actual count and Form 5500 methods are also available. The snapshot count adds the total number of lives covered on one day in each of the first three quarters of the year. The total is divided by three to determine the annual enrollment count.

  • When entering the legal business name, do not include any special characters which include: * < > \ / % ^ ` { } ~ [ ] ! & + = ? , # “ 
  • If you’re a self-insured plan sponsor, under “Entity Type,” enter “SI,” which denotes self-insured.