Posts Tagged: reinsurance fee

PCOR and Reinsurance Fees

in Affordable Care Act

Yesterday I spoke at the 2013 Legislative Meeting of the Society of Professional Benefit Administrators (SPBA) here in Washington DC. One of my co-speakers was Dr. Sharon Arnold from CCIIO – one of the architects of the reinsurance fee program. We were very honored to have such a high-level and knowledgeable person on the panel. The meeting also featured representatives from the IRS discussing the Patient Centered Outcome Research (PCOR) Fee. My discussion focused on the differences between the PCOR Fee and the transitional reinsurance fee. Many of you have already seen and enjoyed our comparative chart (attached). Two quick… Continue Reading

Reinsurance Proposed Regulations – Released

in Affordable Care Act

Additional reinsurance fee guidance was released this morning. We are still pouring over the almost 400-page set of regulations. Clearly, HHS has been busy the last few months, and for the most part the rules are friendly to employer plans. There are a few initial items I wanted to send out today: 1. Wellness Plans and related Disease Management plans are excluded from the reinsurance fees. This is a tremendous win for employers. 2. There is no blanket exception for retiree-only plans. HOWEVER, there is an exception for Medicare-eligible individuals where the employer coverage would be secondary to Medicare. Basically,… Continue Reading

ACA Reinsurance Fee

in Affordable Care Act

Early this year in March, HHS finalized its regulations regarding the reinsurance fee. This fee applies to all employer group health plans starting in 2014. The fee has not been established yet by HHS, but is expected to be in the range of $60-$110 per year, per covered life. The final regulations exempt stand-alone dental and vision benefits, but unfortunately do not exempt other benefits that have been traditionally exempted from the Affordable Care Act mandates. Yesterday, I filed comments with HHS on behalf of certain clients arguing for an exemption from the reinsurance fee for EAPs, wellness programs, health… Continue Reading

What Slowdown in ACA Guidance?

in Affordable Care Act

You may have noticed a recent slowdown in Affordable Care Act guidance, and really any other governmental guidance coming out of HHS, DOL and Treasury. This is not by accident. Unofficially, there is a temporary slowdown in guidance until after the election. After the election passes, you should expect a number of key pieces of Affordable Care Act guidance to drop. This would include the employer penalty under 4980H, how to test for minimum value and additional guidance on the reinsurance fees.