A big, new Patient Protection and Affordable Care Act (PPACA) risk-management program — the “transitional reinsurance program” — is about to start sucking $12 billion out of health insurers and self-insured employer plans with third-party administrators (TPAs) starting Jan. 15, 2014.
The Center for Consumer Information & Insurance Oversight (CCIIO) — the arm of the U.S. Department of Health and Human Services (HHS) that administers the program — has just posted a collection of reinsurance program compliance documents aimed at insurers, employers, TPAs and their professional advisors.
The program is supposed to be transitional and last just three years — but “temporary” government initiatives have been known to last longer than expected, as anyone reading this article while working in a “temporary Quonset hut” office set up during World War II knows very well.
Drafters of PPACA included the section that created the reinsurance program — Section 1341 — in an effort to protect individual major medical premiums against all of the many health insurance market changes made by PPACA. The program calls for all health insurance issuers and self-insured group health plans with TPAs to contribute a fixed amount per enrollee.
The program is supposed to use the cash to protect insurers that issue PPACA-compliant major medical coverage inside or outside the public exchange system against part of the cost of covering enrollees with high medical bills — to compensate for the fact that the insurers now must offer coverage to applicants without considering the applicants’ health status, and without using personal health factors other than age and tobacco use when setting premiums.
In practice, for the insurers, TPAs and employers affected, filing the required employee counts and payments has meant going on a scavenger hunt to find the documents that describe the new system, and understanding the documents has meant spending quality time with compliance lawyers and other experienced readers of federal regulatory documents.
If you are in the insurance market, you may be getting questions in connection with any TPA services your company offers. Or you may be getting questions and comments from clients who know you have nothing to do with their employee counting pain but simply want to complain to someone who understands what they’re going through.
To learn about the tools CCIIO is offering to give employee-counting information, payment-making information and other reinsurance-related information from the horse’s mouth, read on.
CCIIO actually set up the page in July, but the agency has just started to flesh it out with bits of useful information — such as a little table showing when everything is actually due.
A self-insured plan that does not use a TPA will not have to make contributions for the first two years.
But, for organizations that will have to file the employee counts, or pay the reinsurance program bills, CCIIO has just announced that the program filing form will go live on the Web Oct. 24.
- Employee counts will be due Nov. 15, 2014.
- The first payment, for $52.50 per covered life, will be due Jan. 15, 2015.
- A second payment, for $10.50 per covered life, will be due Nov. 15, 2015.
(An entity can simplify life by filing one $63 payment per life Jan. 15, 2015, rather than making one payment Jan. 15, 2015, and a second payment Nov. 15, 2015.)
CCIIO has also expanded the page by providing to links to official documents explaining the reinsurance program that were once available solely to compliance lawyers, big benefits administration firms, and the kinds of wonks who win every game of Clue.
CCIIO once had a semiofficial guide to counting employees for PPACA reinsurance program purposes on Regtap.info — a website that seems to be in a region of Internet limbo. Insiders who know the right Web address can go straight to a Regtap page, but the managers of the site exclude search engines. That means ordinary people cannot find Regtap documents by searching with Google, Bing or even Russian or Chinese search engines.
Some professional services do post searchable links to Regtap documents on the public Web, but it’s not completely clear whether that’s ethical, or even legal.
CCIIO has now broken this batch of reinsurance program guidance on the public Web, where everyone can search for it, read it and link to it without worrying about getting a visit from the Internet police.
The CCIIO guide offers two pages of information about types of coverage that do not have to be included in the reinsurance program employee counts, a discussion of where secondary coverage comes in, and many pages of examples of counting methods.
See also: Feds complete health risk program rules
CCIIO has now liberated several sets of instructions for making reinsurance program payments through the government’s Pay.gov system from Regtap and put them where members of the reinsurance contribution making public can see them.
One of the major slidedecks, used for presentations given this past summer, gives nuts and bolts information about how to sign up for Pay.gov, and what kinds of characters can and cannot go in the documentation supporting the annual enrollment counts.
Other, related documents go into more detail about how to fill out the forms.
If you are the person who is actually responsible for feeding the reinsurance program information into a computer and forcing the computer to get that information into Pay.gov, this guide may help you avoid having to pull an all-nighter to meet the filing deadline.
The guide states, for example, that supporting documentation must be in the .CSV format, and must not be bigger than 2 megabytes.
If you include an asterisk, a plus sign, an ampersand, an exclamation point, or many other types of special characters in your supporting documentation, the supporting documentation will not work.
See also: PPACA plans lurch toward servicing stage