Reinsurance Fee Reporting Deadline DelayedPublications - Client Alert | November 15, 2014
Late Friday, the Centers for Medicare & Medicaid Services ("CMS") extended the November 15 deadline for "contributing entities" to submit their 2014 enrollment counts for the transitional reinsurance program contributions. The new deadline is 11:59 p.m. on December 5, 2014. The payment deadlines remain the same. Given how close to the original deadline the CMS waited before extending it, this relief may be of little use to most contributing entities.
As background, the transitional reinsurance program was enacted as part of the Affordable Care Act ("ACA") to provide reinsurance for certain health insurance policies and help stabilize the costs of premiums. The ACA imposes certain fees to provide the reinsurance. In general, both fully-insured and self-funded major medical plans are considered "contributing entities" that are subject to the fees.