Recently we had a customer ask about this fee after it was brought to their attention by their TPA. Since this a fee on self-funded plans, it has the potential to affect many of our customers who are offering these plans to their employees. We found several helpful links via Google with more details:
The Transitional Reinsurance Program – Centers for Medicare & Medicaid Services
Reinsurance Fact Sheet – Cigna
International Medical Administrators
If you have a self-funded plan and you are not sure whether you need to pay this fee, contact your insurance broker/agent/TPA to find out. If you do need to pay this fee, we recommend using the “snapshot” method as described in the Cigna link to determine the number of covered lives each month. A new report has been added to the HR to determine the number of covered lives per month for each of your health insurance plans. This report is based on the enrollment dates recorded on your health benefit records.
We recommend that you start with this report but confirm the numbers on it with your actual bills for each month from your insurance company that should list how many covered lives there are for each month. (If your detail bills are readily available, your insurance carrier might also be able to provide you with a report with the monthly enrollment counts.)
If there is a difference between the counts from the report and the counts from your bills, we would recommend using the numbers from your bills. A review of your health benefit records may be needed to make sure you have an accurate accounting of who was insured each month, and that the coverage reported on the 1095-C will be accurate. An update will be available soon that includes more options for importing detail insurance bills in Excel format as an aide to reconciling coverage records with billing records.
The latest version of the HR program can be downloaded using the Check for Updates option on the Tools menu. Go to Health Insurance->Reports->Insurance Enrollment Count Report to run the new report that will give you the covered lives per month information.