The Health Care Reform Act created the transitional reinsurance program, which requires most self-insured health plans to make contributions to HHS for the 2014, 2015, and 2016 calendar years. The contribution amount is determined by the number of covered lives under each plan. The number of covered lives must be calculated and submitted to HHS by November 15 of each year. The first filing is due November 15, 2014 for the 2014 calendar year.
Covered lives may be calculated using several different methods, similar to the methods that are used to calculate covered lives for PCORI fees. Contributing entities should begin making these calculations using the various permitted counting methods so that they have time to establish the most cost-effective method for determining their 2014 contribution amount prior to the deadline.
Please see our newsletter, Reinsurance Program Requires Self-Insured Health Plans to File Enrollment Data by November 15 and Pay Fee Later, for more detailed information.