An FAQ regarding transitional insurance fee (TRF) submissions for 2014 appeared on the Centers for Medicare and Medicaid Services (CMS) “REGTAP” site on May 12, 2015. (CMS uses REGTAP to provide information on several different programs it administers, including TRF collections.) The new FAQ indicates that employers may receive emails asking them to provide information so CMS can make sure the appropriate TRF payments were made for 2014.
The FAQ indicates that these requests are going to plans that have already paid the 2014 TRF directly or through a third party, and to plans that had no obligation to complete the 2014 TRF filing in the first place. CMS asks that any employer receiving one of these requests visit to the site indicated and respond to the questions asked “so that CMS can reconcile records.” The request will be received via an email entitled ”ACTION REQUIRED: 2014 Transitional Reinsurance Program Contribution Submission Not Found – Case ID #.”
A TRF Review, In Case You Were Able to Forget…
The TRF is a per capita fee that is to be paid with respect to every individual that has coverage under a policy or plan subject to the requirement (in other words, it applies to enrolled spouses and children, not just employees). Insurers and sponsors of self-insured plans are required to pay the TRF with respect to the major medical coverage they provide.
| IMPORTANT: Employers that did not sponsor a self-insured plan during 2014 were not required to remit the TRF for 2014 or complete the on-line filing through pay.gov. |
You may recall that the TRF is assessed for calendar years 2014, 2015 and 2016. Each year, an entity required to file (an employer sponsoring a self-insured major medical plan) must determine its average enrollment count over the first nine months of the year and then report that count by Nov. 15. The filer does so using an on-line process made available through pay.gov. The on-line facility determines the TRF amount due based on the enrollment count reported, and the filer completes the process by arranging an ACH transfer of that amount. (There is also an option to pay the TRF in two installments.)
The on-line process had a number of difficulties, and employers required to complete it were relieved when they were able to complete it. Once those employers’ ACH transfers cleared, it seemed they could set aside TRF concerns until the 2015 filing.
CMS Is Having Some Issues With the Filings
Apparently, despite its elaborate filing procedure (in which employer plans entered the same information at least three times), CMS is having trouble matching payments to payers, so employers for whom CMS cannot find a filing or a payment will be asked to go through yet another online process so that they can pay (or show that they have already paid) the TRF. It’s not clear why an employer would get thrown into this bucket or how many employers have received greetings from CMS. Apparently CMS issued an FAQ on this process only because it received calls asking whether the request was a legitimate CMS inquiry or some type of phishing effort. The FAQ assures us that these are indeed CMS requests.