ACA’s Transitional Reinsurance Fee Due for Self-Insured Employers– November 10, 2014

Self-insured employers need to be mindful of two important Affordable Care Act (ACA) deadlines — the Transitional Reinsurance Fee and the Patient Centered Outcomes Research Institute (PCORI) Trust Fund Fee.

Transitional Reinsurance Fee

The most imminent deadline is November 15, 2014, by which time self-insured employers must submit a plan enrollment count to the Department of Health and Human Services (HHS) to establish their 2014 Transitional Reinsurance Fee. Here is what you need to know:

  • Employers must register their business and submit the appropriate supporting documentation at www.pay.gov.
  • The 2014 fee is $63 per covered employee.
  • The only payment method accepted is an ACH debit.
  • Employers do not have to pay the total fee due until January 15, 2015, but bank information must still be included on the registration form.
  • Employers can select a future date for the transaction to take place.
  • The fee is tax deductible as an ordinary and necessary business expense.

Please note that if your health plan is fully insured, your insurance carrier is responsible for filing the form and paying this fee.

The Transitional Reinsurance Program was established under Section 1341 of the ACA. This fee is currently set to be collected for years 2014 through 2016 and was implemented to stabilize premiums for coverage in the individual market. The reinsurance fee will be distributed to health insurance issuers in the non-grandfathered individual market that is assumed to attract a large number of enrollees at risk for high medical costs. The fee for 2015 is set to be $44 per covered employee; the fee for 2016 has yet to be determined.

Patient Centered Outcomes Research Institute (PCORI) Trust Fund Fee

This is another fee for self-insured employers to have on their radar, although a bit farther down the road. Below is what you need to know about the PCORI fee:

  • It is due July 31, 2015.
  • The per-capita fee for plan years ending after September 30, 2014, and before October 1, 2015, is $2.08, which is based on average plan enrollment over the plan year.
  • This fee must be paid annually using Form 720 (Quarterly Federal Excise Tax Return) by July 31 of each year.
  • The fee was established under Section 6301 of the ACA and is earmarked for research that will support patients, clinicians, purchasers and policy makers in making better informed health decisions.

In addition to meeting the above deadlines, individuals will also have to report their health care coverage to the IRS in the upcoming tax filing season. So, stay tuned for more information in the near future.

We want to hear from you! We encourage you to comment below on this blog post, share it on social media or contact Stephanie Daniels at sdaniels@cohencpa.com or Maura Corrigan at mcorrigan@cohencpa.comfor further discussion.

This communication is published by Cohen & Company for our clients and professional associates. Cohen & Company is not rendering legal, accounting or other professional advice. Any action taken based on information in this publication should be taken only after a detailed review of the specific facts and circumstances.