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Oct 08

Jessica Rothe

Regulatory Reporting Update – Transitional Reinsurance

by Jessica Rothe

Review of Transitional Reinsurance:

Healthcare reform requires self-funded group health plans to fund a Transitional Reinsurance Program from 2014 to 2016. The purpose of the program is to help offset the high medical costs of individuals enrolled in the non-grandfathered individual market.

Reporting Requirements and Fees:

In 2015, the Transitional Reinsurance Fee decreased to $3.67 per member per month, or $44 per member annually (down from $63 per member annually). This amount is expected to decrease again in 2016. Self-insured group health plans are responsible for reporting employee totals and remitting payment of the fee. Member totals of the plan (or plans) must be submitted to Health and Human Services (HHS) by November 15, 2015 at These totals are based on the first nine months of the calendar year. There is a choice as to whether to pay the assessed amount in one installment (all payment owed invoiced by December 15, 2015) or two installments (amounts separated with the reinsurance contribution invoiced December 15 and the amounts allocated to the US Treasury invoiced in the fourth quarter of 2016).

Submission and Additional Resources:

CMS has put on a series of webinars and other informational resources to help with the submission and payment process. These resources can be found by registering for a free account with CMS through the Registration for Technical Assistance Portal (“REGTAP”) online at Once logged in, search for Reinsurance, to view and download the materials. All submissions and payment will be handled through, which also requires registration to use.

Disclaimer: The information contained herein is not intended to be legal advice, and while every effort has been made to ensure that the content of this legislative summary is accurate, we makes no representations or warranties in relation to the information provided, and assumes no liability or responsibility for any acts or omissions based on this information. As always, we encourage you to consult with your own legal counsel prior to making any decisions regarding plan design or administration.