Here We Go Again. Navigating the Online System for Paying the Transitional Reinsurance Fee (TRF) HEALTH REFORM ADVISORY PRACTICE

Transcription

1 HEALTH REFORM ADVISORY PRACTICE Here We Go Again Navigating the Online System for Paying the Transitional Reinsurance Fee (TRF) Presented by Mark Holloway, J.D. Compliance Services, Lockton Benefit Group Lockton Benefit Group 2015 To View Webcast, Click Here

2 PLEASE NOTE: The audio portion of this presentation will be broadcast through your PC. Please DO NOT attempt to dial in to the webcast on your telephone. 2

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6 Upcoming Webcasts November 19 Qualifying Events: The Old and the New 3d0b26d11d5e5f04f1 6

7 HEALTH REFORM ADVISORY PRACTICE Here We Go Again Navigating the Online System for Paying the Transitional Reinsurance Fee (TRF) Presented by Mark Holloway, J.D. Compliance Services, Lockton Benefit Group Lockton Benefit Group 2015 To View Webcast, Click Here

8 Agenda

9 Agenda Background on Transitional Reinsurance Fees (TRFs) What s New for 2015? Eight-Step Program for TRF Form Completion Helpful Resources from Uncle Sam Questions 9

10 Background: TRF

11 TRF 101 Transitional Reinsurance Fee TRF = annual per capita fee $44 per enrollee for 2015 ($63 for 2014) $27 per enrollee for 2016 Funds Transitional Reinsurance Program Established under Affordable Care Act (ACA) to help stabilize premiums in the individual market Administered by Centers for Medicare and Medicaid Services (CMS) CMS calls TRF reinsurance contributions Required for 2014, 2015 and 2016 calendar years CMS calls these benefit years 11

12 Which Employer Plans are Subject to the TRF? TRF applies to employer-sponsored health plans providing minimum value (MV) coverage Plan = ERISA definition (without the church and governmental exclusions) MV = Same meaning as for play or pay MV Coverage: 60% actuarial value Use MV calculator to determine whether coverage is MV In some cases, may need an actuarial certification of value Self-funded employers will owe the fee TPA can pay on behalf of plan and invoice the employer Employer can pay the fee itself That s what we ll discussing here... 12

13 Who is Responsible for Filing and Remitting? Structure TRF Required? Who Files and Remits TRF? Enrollees Excluded from Being Counted Insured MV Plan (Employer provides NO self-insured health benefits other than disregarded benefits * ) Yes Insurer Those not actually covered by MV medical coverage on the counting date (e.g., only covered for dental, vision or EAP benefits) Those covered by Medicare for whom Medicare is primary Those covered by an individual policy for which TRF is being paid Those covered by another employer plan that is primary Self-Funded MV Plan (Employer provides NO insured health benefits other than disregarded benefits * ) Yes Plan Sponsor Those covered by expatriate health insurance Individuals whose primary residence is in a U.S. Territory * Disregarded benefits include: Integrated health reimbursement account (HRA) Plan with Self-Funded MV Option and Insured MV Option (No benefits available in addition to the MV options other than disregarded benefits * ) Multiple Employer- Sponsored Plans Simultaneously Providing Coverage to a Single Individual Yes Yes, if combined coverage is MV Plan Sponsor for Self-Funded MV Options Insurer for Insured MV Options Varies CMS rules determine Health flexible spending account (FSA) offered under a cafeteria plan Health savings account (HSA) Prescription drug coverage Optional dental or vision coverage On-site clinic Dread-disease/specified illness insurance Hospital or other fixed indemnity insurance Medicare or TRICARE supplement insurance Other excepted benefits Disregarded Benefits * No 13

14 What s New for 2015

15 Differences In TRF Process for 2015 Fee is $44 for 2015 (vs. $63 in 2014) Supporting documentation (.csv file) for the TRF submission only required if submitting contributions for four (4) or more plans Unusual that an employer would submit for that many plans Practical impact insurers and TPAs will may need to attach supporting documentation, but most employers will be exempt Contributions are not required from a selfinsured group health plan that does not use a TPA in connection with claims processing or claims adjudication (including the management of internal appeals) or plan enrollment (ditto for 2016) Concession to Taft-Hartley plans 15

16 CMS s Eight-Step Program

17 By November 16, CMS Diagram of Online Process 17

18 Step 1: Before Getting Started Determine annual enrollment count (using an approved method, rounded to nearest hundredth) for the 2015 calendar year Enrollment is measured on a calendar year basis no matter what your plan year is (exception: using 5500 method for annual enrollment count) Not even really a calendar-year basis use the enrollment counts from the first 9 months of 2015 as a proxy for enrollment throughout 2015 Four methods available Actual count on each day January 1 - September 30, 2015 divided by number of days Actual count on at least one day during each of the first three calendar quarters of 2015 divided by the number of days on which counts were taken Same number of days must be used each quarter Day(s) chosen for each quarter must correspond to one another and be within the same week Using the same method to choose days for counting, add together: Actual count of participants with self-only coverage 2.35 multiplied by actual count of participants with other than self-only coverage From most recently filed Form 5500, items 5 and 6, add together number of participants at beginning of plan year and number at end of plan year If plan provides no dependent coverage (only coverage available is self-only), divide total by 2 18

19 Step 1: Before Getting Started Count ALL covered individuals who have MV coverage under the plan for which employer is filing Employees, contractors, directors, staffing agency workers, etc. Retirees (but may be able to exclude some for whom Medicare is primary) Spouses, children, domestic partners, etc. of any of the foregoing Do not count covered enrollees whose MV coverage is: Secondary to Medicare under MSP rules (individual must actually have at least Part A in effect to be excluded) Secondary to another employer s plan for which TRF will be paid (probably need a written acknowledgement from the other plan) In addition to individual market coverage for which TRF will be paid Expatriate insurance coverage Do not count enrollees residing in US territories 19

20 Step 2: Navigate to Form on Pay.gov Note: you had to register at pay.gov last year for the 2014 filing If you haven t logged into pay.gov since 2014, you will be prompted to change your password Information needed for the 2015 form includes: Name and contact information for the person who will be entering the information throughout the process Needs to be someone who can discuss the information submitted on the Form and supporting documentation (including enrollee count reported) Legal business name and employer identification number of plan sponsor Plan sponsor is identified on Form 5500 Important to verify the EXACT legal business name that goes with the EIN Complete the Pay.gov registration with that exact legal business name (EIN won t be needed for registration) Billing address of the plan sponsor 20

21 Registering On Pay.gov Go to click on Register 21

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24 Step 2: Navigate to Form On Pay.gov Once registered, log in to Pay.gov website ( In search box at bottom of page, search for 2015 ACA Transitional Reinsurance Program Annual Enrollment and Contributions Submission Form Once found, select Continue to the Form Then Acknowledge Payment Method in order to navigate to the form itself Only option for payment is ACH (pull from bank account) 24

25 Step 3: Completing TRF Form Contact Information Information Needed To Complete the Form on Pay.gov Legal business name of plan sponsor (auto-populates from Pay.gov) Plan sponsor EIN Billing contact information Billing address (auto-populates from Pay.gov) Contact for Submission Auto-populates from Pay.gov with information of person completing the Form Only one contact for submission required for form required two more individuals be designated 25

26 Step 3: Completing TRF Form Contact Information Sample Completed Form Contact Information 26

27 Step 3: Completing TRF Form Contact Information Next come the following two questions: Are you reporting more than three (3) Contributing Entities? Are you both the Reporting Entity* and Contributing Entity**? If the employer is submitting the TRF form for its own plan, answer yes If you checked yes to the question Are you reporting more than three (3) Contributing Entities? then you will also need to upload supporting documentation later * Contribution entity means the health plan subject to the TRF **Reporting entity means the entity (employer) actually filing the TRF 27

28 Step 4: Completing TRF Form Contributing Entity Information Enter information noted on the form noted below and either continue, save or preview 28

29 Step 5: Complete Contributions Form Need to select New for Type of Filing Select Type of Payment First collection pay $33.00 per enrollee no later than January 15, 2016 Second collection pay the remaining $11.00 per enrollee by no later than November 16, 2016 Later, you must duplicate the first collection form and complete a second submission to schedule payment for second collection OR Combined collection - pay full $44.00 per enrollee no later than January 15,

30 Step 5: Complete Contributions Form Select 2015 from drop-down menu and enter and verify total determined using approved counting method as Annual Enrollment Count Round to the nearest hundredth (e.g., 68.75, not ) 30

31 Step 5: Complete Contributions Form Acknowledgment and Authorizing Official Information After entering count, TRF is calculated To complete the Form: Must check a box next to a verification statement The Gross Annual Enrollment Count entered in this form matches the aggregate enrollment count by entity in the supporting documentation, if applicable. Must check a box next to an acknowledgement statement Acknowledgment: My acknowledgment is on behalf of my organization and the contributing entity or entities for which the data and accompanying payment(s) are being submitted. My acknowledgment legally and financially binds my organization and each contributing entity to the applicable laws, regulations and program instructions of the Affordable Care Act (ACA). By my submission, I certify that the data are true, correct and complete. If my organization or any contributing entity becomes aware that data are untrue, incorrect or incomplete, CMS shall be promptly informed. If CMS identifies a discrepancy or has questions about the data being submitted, I agree to be the contact for responding to such questions. I acknowledge that the provisions of the Affordable Care Act specifically make payments made by or in connection with an Exchange subject to the False Claims Act if those payments include any Federal funds. This includes, but is not limited to, the transitional reinsurance program established under Section 1341 of the Affordable Care Act. Must provide information for an authorizing official who has authority to authorize the TRF payment and certify information is accurate and complete CMS will contact authorizing official if it identifies a discrepancy or has questions 31

32 Step 6: Upload Information.CSV File (if applicable) Complete this step only if you are reporting for three or more plans ( contributing entities ) Select Browse, then attach the.csv file 32

33 Step 6: Upload Information.CSV File (if applicable) Very nearly the same information already entered on the Form, submitted in a.csv file format (assuming plan sponsor is reporting) One line of 14 data elements separated by commas Reporting Entity Legal Business Name (LBN) = Plan Sponsor LBN from Pay.gov Reporting Entity Federal Tax Identification Number (TIN) = Plan Sponsor EIN Contributing Entity Legal Business Name (LBN) = Plan Sponsor LBN Contributing Entity Federal Tax Identification Number = Plan Sponsor EIN Contributing Entity Organization Type = For Profit or Nonprofit Contributing Entity Billing Address Line 1 = Plan Sponsor Address Contributing Entity Billing Address Line 2 (optional, but leave blank if none) Contributing Entity Billing Address City = Plan Sponsor Address City Name Contributing Entity Billing Address State = Plan Sponsor State (2-Letter Abbr.) Contributing Entity Billing Address Zip Code plus 4 = Plan Sponsor Zip Code Contributing Entity Domiciliary State = Plan Sponsor State (2-Letter Abbr.) Benefit Year = 2015 Annual Enrollment Count = Same as Gross Annual Enrollment Count on Form Type of Contributing Entity = SI (or may be MGHPM or MGHPS ) Omit special characters: * < > / \ % ^, +? { } [ ]! ~ & = 33

34 Step 7: Completing TRF Form Payment Information Payment Information Page Select payment date(s) Choice of paying in a single, lump sum ( combined collection ) or in two collections See next slide Enter account holder name Select checking or savings account type Enter bank routing number Enter bank account number 34

35 Step 7: Completing TRF Form Payment Information Payment date pre-populates for the next business to pay Must update payment date field if you wish to schedule ACH transfer for later date No later than January 15, 2016, if either Combined Collection or First Collection No later than November 16, 2016 if Second Collection Must duplicate the first collection form and complete a second submission to schedule payment for second collection ($11 per capita) See slides that follow 35

36 Step 7: Completing TRF Form Payment Information Scheduling Second Collection Navigate to View my Forms on pay.gov 36

37 Step 7: Completing TRF Form Payment Information Scheduling Second Collection Select Duplicate link Then follow steps to select second collection date (see next slide) 37

38 Step 7: Completing TRF Form Payment Information Scheduling Second Collection Schedule second payment date 38

39 Step 7: Completing TRF Form Payment Information Important Reminder Second Collection for 2014 Due Soon Companies that chose second collection for 2014 TRF will owe $10.50 per covered life by November 15, 2015 Option was to pay 2014 fee in one collection ($63) or two collections ($52.50/$10.50) Payment date scheduled for second collection when 2014 submission count submitted Best advice you ll get from this webcast: Good idea to ensure there is money in your bank account to pay Uncle Sam when the second ACH transfer hits 39

40 Step 8: Review and Submit Payment Review submission, below Good idea to select confirmation of transmission 40

41 Step 8: Review and Submit Payment Review authorization and submit payment, and you will then be prompted to print receipt (recommended) 41

42 Step 8.5: Ensure Your Bank Allows the ACH Transfer More sage advice: Check with your bank to see if the account is subject to an ACH debit block If so, the bank needs an identifier so ACH transfer will not be blocked Agency Location Code or ALC+2 For TRF payments: Same codes as 2014 submissions 42

43 Resources On TRF From the Feds CMS page for TRF Initiatives/Premium-Stabilization-Programs/The- Transitional-Reinsurance-Program/Reinsurance- Contributions.html Reinsurance Contribution Submission Hotline Regtap (CMS portal) 43

44 Resources On TRF From the Feds Supporting materials for TRF submission process are contained in Regtap, CMS s portal that is committed to providing technical assistance and training related to Marketplace and Premium Stabilization programs guidance and operations. You will need to register with Regtap if you want access to CMS s materials posted there 44

45 Resources On TRF From the Feds Once registered, log in and navigate to Library 45

46 Resources On TRF From the Feds Filter by reinsurance contributions 46

47 Questions? 47

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