Self Insured Plans: Instructions for Reinsurance Contributions and Obtaining a HPID

Transcription

1 Self Insured Plans: Instructions for Reinsurance Contributions and Obtaining a HPID 9/30/2014

2 Agenda Reinsurance Contribution o Reinsurance Overview o Registering on Pay.gov o Completing the Form o Preparing Supporting Documentation o Scheduling Payment Applying for HPID o Health Plan Identifiers o HPID Application Process Today s Speakers Katharine Marshall, JD Compliance Officer Lindsey Surratt, JD Compliance Officer This presentation provides information of a general nature and should not be regarded as legal or tax advice and cannot be relied upon as a substitute for legal or tax advice. Receipt and review of this presentation does not create an attorney client relationship. 2

3 Reinsurance Contribution: Overview 3

4 Reinsurance Program Three year period beginning January 1, 2014 Expected to raise 2014 $12 Billion 2015 $8 Billion 2016 $5 Billion Cost to employer sponsored group health plans o $63 per covered life in 2014 o $44 per covered life in 2015 o $26 per covered life in 2016 (estimate) 4

5 Plans and Payers Self insured plans o ASO/TPA may assist with reporting annual enrollment count and scheduling payment of contribution o Plan sponsor must pay the Reinsurance either directly, or through the ASO/TPA Fully insured plans o Carrier will complete the process and pay the fee on behalf of the plan Reinsurance Contributions apply to major medical group health plans o Reinsurance contributions not required for HRA s that are integrated with the major medical plan 5

6 Reporting Annual Enrollment Count Annual enrollment count must be reported to HHS via pay.gov by November 15 th The associated Reinsurance Contribution is automatically estimated by HHS Payment dates and payment information must be provided to complete the process 6

7 Calculating Contribution Amounts Contribution amounts are calculated by multiplying the annual enrollment count by the annual per covered life contribution rate ($63) Annual enrollment count is determined by using one of 3 methods approved for self insured plans o Actual Count Method o Snapshot Count or Snapshot Factor Methods o Form 5500 Method 7

8 Payment Options Schedule first payment for no later than January 15, 2015 o $52.50 of the $63 for each enrollee Schedule second payment for no later than November 15, 2015 o OR $10.50 of the $63 for each enrollee Schedule full payment for no later than January 15, 2015 o Full $63 for each enrollee 8

9 Contribution Submission Process To successfully complete the reinsurance contribution process, contributing entities must: o Register on Pay.gov o Access the ACA Transitional Reinsurance Program Annual Enrollment and Contributions Submission Form o Schedule payment for calculated reinsurance contributions on the payment page 9

10 Contribution Submission Process 10

11 Reinsurance Contribution: Registration on Pay.gov 11

12 If your organization does not have a Pay.gov account, you will need to register 12

13 Pay.gov Registration Page 13

14 Company Name & Address After completing the required fields of the registration page, complete the company name and company address information so that it will pre populate in the Form 14

15 Reinsurance Contribution: Completing the Form 15

16 After Registering on Pay.gov Log into Pay.gov and search for the appropriate form ACA Transitional Reinsurance Program Annual Enrollment and Contributions Submission Form THE FORM 16

17 Reinsurance Submission Form Overview o Collects demographic and contact information for the reporting entity o Requires entry of the Gross Annual Enrollment Count o Provides auto calculation of contribution amount o Requires selection of Type of Payment 17

18 Reinsurance Submission Form The Legal Business Name (LBN), Billing Address and Contact 1 for Submission are auto populated from the Pay.gov profile 18

19 Contact Information The Form requires the name and contact information for three people o The first contact auto populates from the Pay.gov profile o Information provided should be for whomever can discuss information submitted on the Form and supporting documentation 19

20 Type of Payment Select Type of Payment based on how you intend to make the Reinsurance payment o First Collection deadline is January 15, 2015 o Second Collection deadline is November 15, 2015 o Combined Collection (one complete payment) deadline is January 15,

21 Type of Payment HCW recommends you select Combined Collection as Payment Type o This allows you to submit the Form just once If you select First Collection, you will have to submit the Form a second time for the Second Collection 21

22 Select Benefit Year for Reporting Enrollment Count Select 2014, regardless of plan year. The Reinsurance fee is calculated based on enrollment count in the 2014 calendar year. 22

23 Gross Annual Enrollment Count In the Gross Annual Enrollment Count field, enter the annual enrollment count generated using one of the approved counting methods In the Verify Gross Annual Enrollment Count field, enter the same number 23

24 Verification and Acknowledgement Verification o You must check the box next to the statement: The Gross Annual Enrollment Count entered in this form matches the aggregate enrollment count by entity in the supporting documentation. Acknowledgement o You must also check a box next to the Acknowledgement statement (next slide) 24

25 Acknowledgment Statement 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. 25

26 Authorizing Official Provide the appropriate information for the individual that authorizes the Acknowledgement o The individual entered as the Authorizing Official should have authority to authorize the payment transaction and certify that the data is true and correct o CMS will contact the Authorizing Official if a discrepancy is discovered or if there are questions about the data submitted 26

27 Reinsurance Contribution: Preparing Supporting Documentation 27

28 Supporting Documentation Supporting Documentation Requirements o The file must be a.csv file format o The file must not exceed 2MB o The file must not contain any Special Characters Special Characters * < > \/ % ^ ` { } ~ [ ]! & + =? A Job Aid will be available for to assist reporting entities in creating the supporting documentation file 28

29 Supporting Documentation 29

30 Supporting Documentation Field Reporting Entity Legal Business Name (LBN) Reporting Entity Federal Tax Identification Number (TIN) (include the hyphen) Contributing Entity Legal Business Name Contributing Entity Federal Tax Identification Number (TIN) (include the hyphen) Field Contributing Entity Billing Address City Contributing Entity Billing Address State Contributing Entity Billing Address 5 digit Zip Code (plus 4 if available) Contributing Entity Domiciliary State (state where incorporated) Contributing Entity Organization Type (for profit or nonprofit) Benefit Year (must be 2014) Contributing Entity Billing Address Line 1 Contributing Entity Billing Address Line 2 Annual Enrollment Count (number of covered lives) Type of Contributing Entity (SII for Self Insured) Note: If you are self reporting an employer sponsored plan, the reporting entity and the contributing entity are the same = the plan sponsor. Reminder: If the Legal Business Name contains special characters, be sure they are omitted in this supporting documentation file. 30

31 Reinsurance Contribution: Scheduling Payment 31

32 Payment Method and Amount Payments must be made on Pay.gov using an Automated Clearing House (ACH) payment o Only one bank account may be entered per Form o In order to allow for auto debit, you must have the appropriate Agency Location Code (ALC+2) added to the allowed list of ACH company IDs o You must contact your bank to have the ALC+2 value added: Payment Amount is auto populated o Based on the Type of Payment selection and the calculated contribution amount 32

33 Scheduling Payment Payment Date will be auto populated with the next business day o CMS recommends you change the payment date to be at least 30 days after the date of Form submission, but before the deadline o For example, if you submit the Form on November 2, 2014, CMS recommends that the selected payment date be no earlier than December 2, 2014 January 15, 2015 Deadline for 1st contribution and combined collection November 15, 2015 Deadline for the 2nd contribution 33

34 Other Payment Information Payment Date Enter the Account Holder Name Select Checking or Savings Account Type Enter Bank Routing Number Enter Bank Account Number o If you previously made a payment through Pay.gov, the banking information previously entered may pre populate; you will have the option to change it 34

35 Reinsurance Contribution: Preparation 35

36 Review NOW! Schedule Payment to Occur Before January 15, 2015 Complete Steps 1, 2, 3 and 4 before November 15 36

37 Preparation Checklist Contact your bank to have the ALC+2 value added to allow for auto debit Reporting Entity s Legal Business Name (LBN) Reporting Entity s Federal Tax Identification Number (TIN) Reporting Entity s Billing Contact Name, Title, Address and Phone Number Reporting Entity s Billing Address Reporting Entity's Two Additional Submission Contacts Name, Title, Address and Phone Number 37

38 Preparation Checklist Continued Contributing Entity s 2014 Annual Enrollment Count Provided by HCW for clients not relying upon their ASO to complete the Reinsurance Contribution process on their behalf Expect an communication with this information from a member of your HCW team in the next few weeks Authorizing Official Name, Title, Address and Phone number Account Holder Name Account Type (Checking or Savings) Bank Routing Number Bank Account Number 38

39 Additional Requirements Maintenance of records: Each contributing entity must maintain and make available documents and records sufficient to substantiate the enrollment count submitted, for a period of at least 10 years Audits: HHS has authority to audit a contributing entity to assess its compliance with the requirements of the transitional reinsurance program 39

40 More Information The Transitional Reinsurance Program Reinsurance Contributions Webpage and Initiatives/Premium Stabilization Programs/The Transitional Reinsurance Program/Reinsurance Contributions.html 40

41 Health Plan Identifiers 41

42 Background HIPAA standard transaction rules introduced in 2000 o Rules apply to HIPAA covered entities (health plans, healthcare providers, clearinghouses) Business associates of health plans typically conduct HIPAA standard transactions, including (but not limited to): o Claims and encounters o Premium payment and remittance advice o Authorization and referrals o Electronic funds transfer (EFT) 42

43 Background Beginning in 2014, health plans must start obtaining health plan identifiers (HPIDs); a year later, they must certify compliance with the HIPAA standard transaction rules by filing an attestation Want more information? What is an HPID? An HPID is a 10 digit unique identifier that will be used to identify health plans in HIPAA electronic standard transactions Why are HPIDs required? Requiring all health plans to have a unique identifier in a standardized format is designed to make these electronic transactions more accurate and efficient 43

44 Which Plans Must Obtain an HPID? Controlling Health Plans (CHPs) are required to obtain an HPID. A CHP is a health plan that: o o controls its own business activities, actions, or policies; or is controlled by an entity that is not a health plan. CHPs include: o o Group health plans Major medical, HRA, health FSA Dental, Vision, EAP, LTC, cancer only, fixed indemnity If these are bundled or wrapped with other benefits, they may be considered subhealth plans health insurance issuers Common CHPs include: o o o Insurer for fully insured group health plan Self insured group health plan (even if it does not conduct HIPAA standard transactions) Self insured HRA (or health FSA) paired with a fully insured group medical plan 44

45 HPID and Certification Timing Large health plans (greater than $5 million in annual receipts) Small health plans ($5 million or less in annual receipts) New Health Plans HPID Deadline Certification/Attestation Deadline November 5, 2014 December 31, 2015 November 5, 2015 December 31, 2016 One year after obtaining HPID NOTE: Health plans that are self funded and self administered with fewer than 50 participants are exempt. All other health plans must comply by these deadlines. HPIDs must be in use in all standard transactions by November 7,

46 HPID Application Process 46

47 Who Applies for the HPID? For a fully insured group health plan: o The health insurance carrier For a self funded group health plan: o The self funded group health plan TPAs are not permitted obtain the HPID on behalf of a self funded group health plan, but the TPA may need to use the HPID obtained by the self funded group health plan Even if the TPA is using its own OEID (other entity identifier), the selffunded group health plan must still obtain an HPID 47

48 The HPID Application Process 48

49 Step 1 Register in HIOS Access the CMS Health Insurance Oversight System (HIOS) ( o HPID obtained through HPOES (Health Plan and Other Entity Enumeration System) To determine if the organization already exists in HIOS, search by the organization s federal EIN New HIOS users must register in the Enterprise Portal to obtain a user ID and password o o Registration process requires Identity Verification (ID Proofing) Social Security Number, Date of Birth, Home Address and Primary Phone Number Health plan can begin application process NOW 49

50 Step 1 Register in HIOS 50

51 Step 1 Register in HIOS 51

52 Step 1 Register in HIOS 52

53 Step 1 Register in HIOS 53

54 Step 1 Register in HIOS 54

55 Step 1 Register in HIOS 55

56 Step 1 Register in HIOS 56

57 Step 2 Access HIOS User Role Management Users will need to determine their user role and identify the company to which they need access. There are three different HPOES user roles: Guest User: A user that is able to view general HPOES information (no company association needed). Submitter User: A representative of a health plan or other entity that submits an application. Authorizing Official User: A company executive that has the authority to approve applications, including CEOs and CFOs. *NOTE: If requesting the Submitter or Authorizing Official role, users will need to identify the company to which they wish to be granted access. Users can only have one HPOES role at a time. 57

58 Step 2 Access HIOS User Role Management 58

59 Step 2 Access HIOS User Role Management 59

60 Step 2 Access HIOS User Role Management 60

61 Step 2 Access HIOS User Role Management 61

62 Step 2 Access HIOS User Role Management 62

63 Step 3 Access HPOES Once you have received the confirmation , access HPOES and select your application type. o Group health plans will select HPID Application There are two different HPID Application Types: o CHP o SHP Controlling Health Plans will select the CHP HPID application 63

64 Step 3 Access HPOES 64

65 Step 3 Access HPOES 65

66 Step 4 Complete and Submit Application If the User Role selected in Step 2 was Submitter then the Authorizing Official will need to be identified in this step o If an Authorizing Official has already been selected for an entity, the information of the Authorizing Official will be prepopulated in the application 66

67 Step 4 Complete and Submit Application 67

68 Step 4 Complete and Submit Application 68

69 Step 4 Complete and Submit Application 69

70 Step 4 Complete and Submit Application 70

71 Step 4 Complete and Submit Application 71

72 Step 5 Application and Review by Authorizing Official Once the application has been submitted, the company s Authorizing Official will be notified by that an application is pending their approval o The Authorizing Official will need to review each application and will have the option to approve or reject it 72

73 Step 5 Application and Review by Authorizing Official 73

74 Step 5 Application and Review by Authorizing Official 74

75 Step 5 Application and Review by Authorizing Official 75

76 Step 5 Application and Review by Authorizing Official 76

77 Step 6 HPID Assigned Once the application is approved by the Authorizing Official, the system will generate the HPID An notification will be sent to the submitter user with the HPID 77

78 Health Plan Certification and Attestation Requirements Health plans must file two certifications attesting that the plan is in compliance with the Standard Transaction Rules o Requirement applies even if all health plan standard transactions are completed by a business associates o Both certifications are required only once There is no obligation to update the information or file on a regular basis Currently, proposed rules only exist for the first certification 78

79 Certification and Attestation More information to come! Generally, TPAs for self funded group health plans conduct HIPAA standard transactions on behalf of the plan o It is anticipated that TPAs will obtain the necessary certification of compliance with the HIPAA standard transaction rules o Self funded group health plans will need to: Provide their TPAs with their HPID(s) for any controlling health plans; and Work with the TPA to obtain documentation that the TPA has completed the required certification 79

80 Attestation with HHS After the certification has been obtained, the health plan must file an attestation with HHS The attestation filing requires: o Documentation demonstrating compliance with one of two certifications o Number of covered lives under CHP and any SHPs as of date of filing Will be used for penalty assessments o Signature of senior level executive Indicating the entity is compliant with HIPAA Standard Transaction rules and HIPAA privacy and security rules 80

81 Failure to Certify Penalties Failure to Certify o $1 per covered life per day until the certification is made (up to a max of $20 per covered life) Knowingly providing inaccurate or incomplete information o $40 per covered life Penalties will increase in future years HHS to match HPID registration to certification filing to find which plans did not file 81

82 Attestation with HHS Controlling Health Plan (CHP) files on behalf on any Subhealth Plans (SHPs) Fully insured health plans o Insurer files attestation Self insured health plans o Health plan files attestation 82

83 Left with Questions?