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- 1 -
Willis Human Capital Practice, National Legal & Research Group
The transitional reinsurance fee (TRF) is one of several implemented under the Patient
Protection and Affordable Care Act (PPACA). The fee was established to stabilize premiums and
mitigate the impact of potential adverse selection in the individual and small group markets.
The enrollment count for 2015, used to calculate the reinsurance fee, is due by November 16,
2015 (as November 15, 2015 is a Sunday). The reinsurance contribution rate for 2015 is $44
(approximately $3.67/ month) per enrolled individual, including dependents. The Department of
Health and Human Services (HHS) offers employers with self-insured plans the option to pay:
(1) the entire 2015 benefit year contribution in one payment no later than January 15, 2016
reflecting $44.00 per covered life; or (2) in two separate payments for the 2015 benefit year, with
the first remittance due by January 15, 2016 reflecting $33.00 per covered life, and the second
remittance due by November 15, 2016 reflecting $11.00 per covered life.
Note: For employers with self-insured group health plans that opted to pay the reinsurance fee in
two installments for the 2014 benefit/calendar year, the second payment is due by November 15,
2015.
Submitting Enrollment Counts
Contributing entities are required to use pay.gov to submit enrollment information and to pay the
reinsurance fee. The 2015 ACA Transitional Reinsurance Program Annual Enrollment and
Contributions Submission Form is available here: https://pay.gov/public/form/start/70746962.
Information on how to submit required data using pay.gov can be found here. Employers can
also refer to Transitional Reinsurance Program Operational Guidance, updated by the Centers for
Medicare and Medicaid Services’ (CMS) for the 2015 year.
CMS is holding an operator-moderated hotline to assist contributing entities in completing the
2015 ACA Transitional Reinsurance Program Annual Enrollment and Contributions Submission
Form. CMS will address individual questions during the scheduled Hotline dates and times listed
below. Questions will be answered in the order in which they are received. All entities dialed
into the hotline can benefit from questions asked and answered. In addition, CMS will respond to
questions sent to ReinsuranceContributions@cms.hhs.gov.
• Tuesday, 11/10/15 – 9:00am – 5:00pm EST
• Wednesday, 11/11/15 – 9:00am – 5:00pm EST
WEEK OF NOVEMBER 9, 2015:
Health Care Reform Update - Reminder: Transitional
Reinsurance Fee Counts Due by November 16
- 2 -
Health Care Reform Update | Willis Human Capital Practice, National Legal & Research Group
• Thursday, 11/12/15 – 9:00am – 5:00pm EST
• Friday, 11/13/15 – 9:00am – 5:00pm EST
• Monday, 11/16/15 – 9:00am – 5:00pm EST
Hotline Access Information:
• Phone: 877-848-1919
• Web: https://regtap.webex.com/regtap/onstage/g.php?d=643910582&t=a
Refund Requests
The rules provide that a contributing entity that correctly applies one of the counting methods
cannot request to change its annual enrollment count and associated payments after the reporting
deadline for the applicable year. See https://www.regtap.info/faq_viewe.php?i=13662. For the
2015 benefit year, permitted refund requests (resulting from annual enrollment count
misreporting) must be submitted 90 days from the date of Form submission. See
https://www.cms.gov/CCIIO/Resources/Regulations-and-Guidance/Downloads/RIC-Guidance-
Refund-Request-Deadline-final-.pdf.
This information is not intended to represent legal or tax advice and has been prepared solely for informational
purposes. You may wish to consult your attorney or tax adviser regarding issues raised in this publication.

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Health Care Reform Developments Week of November 9, 2015

  • 1. - 1 - Willis Human Capital Practice, National Legal & Research Group The transitional reinsurance fee (TRF) is one of several implemented under the Patient Protection and Affordable Care Act (PPACA). The fee was established to stabilize premiums and mitigate the impact of potential adverse selection in the individual and small group markets. The enrollment count for 2015, used to calculate the reinsurance fee, is due by November 16, 2015 (as November 15, 2015 is a Sunday). The reinsurance contribution rate for 2015 is $44 (approximately $3.67/ month) per enrolled individual, including dependents. The Department of Health and Human Services (HHS) offers employers with self-insured plans the option to pay: (1) the entire 2015 benefit year contribution in one payment no later than January 15, 2016 reflecting $44.00 per covered life; or (2) in two separate payments for the 2015 benefit year, with the first remittance due by January 15, 2016 reflecting $33.00 per covered life, and the second remittance due by November 15, 2016 reflecting $11.00 per covered life. Note: For employers with self-insured group health plans that opted to pay the reinsurance fee in two installments for the 2014 benefit/calendar year, the second payment is due by November 15, 2015. Submitting Enrollment Counts Contributing entities are required to use pay.gov to submit enrollment information and to pay the reinsurance fee. The 2015 ACA Transitional Reinsurance Program Annual Enrollment and Contributions Submission Form is available here: https://pay.gov/public/form/start/70746962. Information on how to submit required data using pay.gov can be found here. Employers can also refer to Transitional Reinsurance Program Operational Guidance, updated by the Centers for Medicare and Medicaid Services’ (CMS) for the 2015 year. CMS is holding an operator-moderated hotline to assist contributing entities in completing the 2015 ACA Transitional Reinsurance Program Annual Enrollment and Contributions Submission Form. CMS will address individual questions during the scheduled Hotline dates and times listed below. Questions will be answered in the order in which they are received. All entities dialed into the hotline can benefit from questions asked and answered. In addition, CMS will respond to questions sent to ReinsuranceContributions@cms.hhs.gov. • Tuesday, 11/10/15 – 9:00am – 5:00pm EST • Wednesday, 11/11/15 – 9:00am – 5:00pm EST WEEK OF NOVEMBER 9, 2015: Health Care Reform Update - Reminder: Transitional Reinsurance Fee Counts Due by November 16
  • 2. - 2 - Health Care Reform Update | Willis Human Capital Practice, National Legal & Research Group • Thursday, 11/12/15 – 9:00am – 5:00pm EST • Friday, 11/13/15 – 9:00am – 5:00pm EST • Monday, 11/16/15 – 9:00am – 5:00pm EST Hotline Access Information: • Phone: 877-848-1919 • Web: https://regtap.webex.com/regtap/onstage/g.php?d=643910582&t=a Refund Requests The rules provide that a contributing entity that correctly applies one of the counting methods cannot request to change its annual enrollment count and associated payments after the reporting deadline for the applicable year. See https://www.regtap.info/faq_viewe.php?i=13662. For the 2015 benefit year, permitted refund requests (resulting from annual enrollment count misreporting) must be submitted 90 days from the date of Form submission. See https://www.cms.gov/CCIIO/Resources/Regulations-and-Guidance/Downloads/RIC-Guidance- Refund-Request-Deadline-final-.pdf. This information is not intended to represent legal or tax advice and has been prepared solely for informational purposes. You may wish to consult your attorney or tax adviser regarding issues raised in this publication.