A new flyer is available that explains the minimum essential coverage reporting requirements for section 6055 and 6056 reporting. The summary includes effective dates, who must comply, the reporting mandate and reporting deadlines. More detailed information about what information must be included in the returns to the IRS is also included.
The U.S. Department of Health and Human Services (HHS) has announced a process for the collection of Reinsurance Assessment Fees through the implementation of a system called Pay.gov.
Here are the steps Starmark clients should take to pay the Reinsurance Assessment Fee in a timely manner:
- Register: Plan sponsors must register on Pay.gov.
- Complete the contribution form: No later than Nov. 15 in 2014, 2015 and 2016, plan sponsors need to enter the average number of members in its health plan for the first nine months of the year on a contribution form on Pay.gov. Starmark will provide such count via a letter sent in October.
The contribution form, “ACA Transitional Reinsurance Program Annual Enrollment and Contributions Submission Form,” is expected to be available later this fall. The form requires information for a billing contact and billing address, as well as the name and contact information for plan sponsor contacts. The form will automatically calculate the contribution amount(s).
- Upload: Plan sponsors must upload supporting documentation.
- Enter payment information: Plan sponsors should schedule a payment date by selecting “Type of Payment” based on plan sponsors’ preference on when to make the contribution. The first installment deadline is Jan. 15, 2015, and the second installment deadline is Nov. 15, 2015. Plan sponsors can also pay the fee in full by the deadline of the first installment.
The Centers for Medicare and Medicaid Services is asking that payment dates be at least 30 days after submission of the count to allow for submission count corrections, if necessary. On the Payment Page, plan sponsors will select the payment date, enter the account holder name, select type of account (checking or savings), enter the bank routing number and submit bank account number.
For more information on the Reinsurance Assessment Fee, see the flyer providing further detail.
Note: Register for RegTap to be notified about training on healthcare reform. Webinars about the Reinsurance Assessment Fee are scheduled for Aug. 13, 15, 18 and 22.
 Starmark will use the snapshot count method to count the average enrollment in each client’s health plan.
$52.50 per average covered life
$10.50 per average covered life
The Center for Medicare and Medicaid Services (CMS) recently provided information for plan sponsors of self-funded plans clarifying the process of applying for a Health Plan Identifier (HPID).
Beginning Nov. 7, 2016, a health plan’s HPID must be used when the health plan is identified in a HIPAA standard transaction. According to a representative from CMS, when the HPID application asks for a Payer ID and the self-funded plan’s TPA uses multiple numbers, the user should type, “Not applicable.”
To read more about HPIDs, click here.
The proposed rule requires health plans, including self-funded plans, to submit information and documentation demonstrating compliance with standards and operating procedures for certain electronic transactions. To learn more, view the flyer.
In accordance with the Patient Protection and Affordable Care Act (PPACA) regulations, this week Trustmark is mailing Medical Loss Ratio (MLR) rebate checks with letters to eligible groups as shown below. The size of the group is based on eligible employees.
Small group (based on state definitions, but generally groups with 50 or fewer employees): AR, AZ, GA, IL, IN, KS, MO, MT, NE, NV, OH, TN, TX, UT, VA, WV, WY
Large group (based on state definitions, but generally groups with 51+ employees): AZ, IL, IN, PA, TX, WY
Regulations under the Patient Protection and Affordable Care Act require health insurers to spend at least 80 percent of their premiums on medical expenses for small groups, and at least 85 percent for large groups, or rebate the difference to customers. A lower Medical Loss Ratio (MLR) percentage means a higher potential rebate to the employer. This requirement does not apply to self-funded plans.
Click here to view the MLR rebates Q&A.
A listing of groups and their rebate amounts was emailed to Starmark distribution partners. Groups that are not eligible are not being sent a letter.
The Internal Revenue Service (IRS) has reaffirmed its position on “employer payment plans,” or arrangements in which an employer reimburses its employees for premiums they pay for health insurance (either through a qualified health plan in the Marketplace or outside the Marketplace).
The IRS considers these arrangements to be group health plans, which are subject to Patient Protection and Affordable Care Act (PPACA) provisions, including the prohibition on annual limits and the requirement to provide certain types of preventive care benefits without cost-sharing. These arrangements cannot be combined with individual health insurance policies to comply with PPACA.
Employers found in violation of this IRS ruling could face penalties up to $100 a day per employee.
In addition, the IRS requires that any Health Reimbursement Arrangements (HRA) be paired or “integrated” with a group health plan that is compliant with PPACA.
This week, active Starmark® employers with a self-funded health plan design who are required to pay the Patient-Centered Outcomes Research Institute (PCORI) fee will receive a letter providing their group’s “average covered lives” (using the Snapshot Count method). As a courtesy, the Broker of Record will receive a duplicate copy of the letter sent to their group.
The Patient Protection and Affordable Care Act requires health insurance issuers and plan sponsors of self-funded group policies be assessed an annual PCORI fee, previously known as the comparative effectiveness research fee.
Plan sponsors of self-funded health plans are responsible for filing and paying the PCORI fee. Sponsors of plan years ending in 2013, are required to send the fee to the IRS on Form 720 by July 31, 2014.
For fully insured plans, Trustmark Life Insurance Company is responsible for filing the form and paying the required PCORI fee.
Click here to view a sample letter.