Overpayment of Transitional Reinsurance Fee: Time is Running out for Refund Requests

Refund requests are due to Centers for Medicare & Medicaid Services (CMS) by April 30, 2015, or 90 days from the date of your Form submission, whichever is later. Read more below….

The Affordable Care Act implemented a transitional reinsurance program for collecting contributions from "contributing entities" (insurers and certain self-insured groups offering major medical coverage). The goal is to subsidize insurers for high claim payments on coverage offered through the Marketplace Exchange. The program is effective for the period of 2014-2016.

For the 2014 benefit year, contributing entities were required to submit their annual enrollment count and remit contribution amounts via www.pay.gov , by December 4, 2015. The contribution amount due was auto-calculated by Pay.gov based on the 2014 contribution rate of $63.00 per average covered life.

The Centers for Medicare & Medicaid Services is aware that some contributing entities may have misreported their annual enrollment count, due to misapplication of the permissible counting methods which may have resulted in an overpayment. This error can generally be corrected by the contributing entity refilling a submission Form through Pay.gov.

If a contributing entity believes it overpaid a contribution amount due to misapplication of a counting method, a refund may be available. Refund requests resulting from annual enrollment count misreporting are due to CMS by April 30, 2015, or 90 days from the date of their Form submission, whichever is later. A refund request or questions on the submission process can be sent to reinsurancecontributions@cms.hhs.gov. If the contribution amount payment has already been processed, the submission Form must be refiled with the correct annual enrollment count. CMS will refund the payment associated with the filing error.

This refund notice is only applicable to those contributing entities who incorrectly applied one of the counting methods for determining average lives covered for 2014.  This request and refund is not available for those who correctly applied one of the counting methods and now want to reconsider that method.

For more information on the Transitional Reinsurance Fee please review the following HUB Client Bulletins:

Reinsurance Fee and Related Guidance for 2015

Assessing PPACA Costs: Final Rules for Transitional Reinsurance Fee

Keep visiting HUB International's Health Care Reform blog for implementation news and updates, and get the guidance and resources you need to stay up to date.

Frances K. Horn , J.D., PHR, Chief Compliance Officer for HUB International's Central Region. Her expertise includes all aspects of health care reform, ERISA, COBRA, HIPAA and related statutory and legislative obligations. She regularly conducts seminars and client training on Health Care Reform, Agency Audits, HIPAA and various other compliance issues. Horn holds a Juris Doctorate degree from Duquesne University School of Law and Bachelor of Science degree from Geneva College.