Washington state recently enacted an assessment on health insurance carriers, self-funded MEWAs, and employers that sponsor self-insured plans that cover Washington state residents. These entities will be required to report and pay an assessment on a quarterly basis to the WA Partnership Access Line (“PAL”) Fund for each month in a quarter that the plan covers one or more lives in Washington state.
Overview of the WA Partnership Access Line
The WAPAL Fund was created in 2020 to support funding for the following programs: (1) Partnership Access Line, (2) Mental Health Referral Service for Children and Teens, (3) Perinatal Psychiatry Consultation Line for Providers, and (4) Psychiatry Consultation Line. These programs are overseen by the WA Health Care Authority, however, KidsVax is the entity responsible for administering and collecting assessments under the WAPAL Fund.
Funding of the WAPAL Fund
The WAPAL Fund will be funded through a new assessment imposed on insurance carriers, employers that sponsor self-insured medical plans (including level-funded plans), and self-insured Multiple Employer Welfare Arrangements (MEWAs). Collectively, we will refer to these as ‘Payers’. Payers will be required to make a quarterly contribution to the WAPAL Fund based on the number of covered lives in the plan in Washington state.
The assessment will not only apply to Payers based in Washington state, but to Payers that have any plan that insures or covers Washington residents. The value of the assessment for the second quarter of 2021 was $0. This was the first quarter for which Payers were required to report and pay assessments. However, the assessment due for Q3 of 2021 will be 13 cents per covered life per month. This was released by the newly created WAPAL Fund Advisory Council on September 30. It is due by November 15, 2021.
For future quarters, the assessment rate will be automatically applied to the reported number of covered lives in each quarterly reporting cycle. The KidsVax assessment system will then generate a remittance form Payers can use to pay their quarterly assessments.
Exempt Benefit Plans
The WAPAL Fund assessment does not apply to a health reimbursement arrangement (HRA) that is integrated with an insured or a self-insured medical plan, since those lives are already reported by the other plan. Dental and vision plans are also exempt.
New Reporting Requirements
Payers will be required to report and make quarterly assessments based on the number of covered lives for each month in a quarter. The number of covered lives will be reported based on three age brackets, which will represent the number of covered lives per month for each month within a calendar quarter (a total of nine numbers to be reported per quarter).
- Number of Child-covered lives (ages 0-18)
- Number of Adult-covered lives in band 1 (ages 19-64)
- Number of Adult-covered lives in band 2 (ages 65 and above).
Payers will be required to comply with the reporting requirements described above even if they have zero lives to report for the quarter. The following table discusses the new reporting Payers will be required to comply with:
| Payer Responsibilities | Due on or Before |
|---|---|
| 1. Initial registration and covered lives reporting for the months of April, May, and June 2021. 8/30/21 | 8/30/21 |
| 2. Covered lives reporting and payment with respect to covered lives during July, August, and September 2021 11/15/21 | 11/15/21 |
| 3. Ongoing regular quarterly lives reporting and payment 45th day after each calendar quarter | 45th day after each calendar quarter |
For Q4 of 2021 and future quarters, reports and payment of WAPAL Fund assessment will be due 45 days after the end of the calendar quarter. Or February 15, 2022. For future quarters, reports and payments will be due on May 15 (Q1), August 15 (Q2), November 15 (Q3), and February 15th (Q4) each year. Payers can remit payment by mailing a copy of the remittance form with a check to the P.O. box that appears on the voucher once the reports are submitted or via Automated Clearing House (ACH) transaction.
Payers are required to report the number of covered lives on the following site: https://assessments.wapalfund.org/. The number of covered lives reported must include any individual covered by the plan (insured or self-insured/level funded) that is a Washington resident (individuals residing outside of Washington state should be omitted). Covered lives include active employees, their covered dependents, COBRA qualified beneficiaries, and retirees.
If a Payer ceases to cover any lives in Washington state, the Payer should complete at the beginning of the fiscal year the Zero Covered Yearly Report to indicate the plan will not cover any residents in Washington state.
Next Steps for Employers with Self-insured (Including Level funded) Medical Plans
Employers sponsoring self-insured plans should contact their TPA to ensure that the TPA will assist them with reporting and submitting assessed payments to the WAPAL Fund. If the TPA will not be acting as the reporting entity, the employer sponsoring a self-insured plan will be required to set up their account on https://assessments.wapalfund.org/ to report the number of covered lives and make the payments. If self-insured employers did not set up an account earlier and their TPA fails to assist with reporting or payment, those employers can still set up an account and report for the second quarter of 2021, as there was no fee due for that quarter. Employers who will be required to report directly to the WAPAL Fund can view this training video prepared by KidsVax here: https://www.wapalfund.org/for-payers/resources/. The video discusses step-by-step how to set up an account with the Fund and report the number of covered lives.
Additional information on this new mandate can be retrieved from https://www.wapalfund.org/faqs/. Employers can also contact KidsVax at [email protected] or via phone at 1.855.543.7829 if they have questions regarding the WAPAL Health Fund or if they made underpayments or overpayments of the required assessments.
If you have any questions, please contact your HUB Advisor. View more compliance articles in our Compliance Directory.
NOTICE OF DISCLAIMER
Neither Hub International Limited nor any of its affiliated companies is a law or accounting firm, and therefore they cannot provide legal or tax advice. The information herein is provided for general information only, and is not intended to constitute legal or tax advice as to an organization’s or individual's specific circumstances. It is based on Hub International's understanding of the law as it exists on the date of this publication. Subsequent developments may result in this information becoming outdated or incorrect and Hub International does not have an obligation to update this information. You should consult an attorney, accountant, or other legal or tax professional regarding the application of the general information provided here to your organization’s specific situation in light of your or your organization’s particular needs.