By: Lois Mathis-Gleason, CEBS
Updates:
On November 14, 2014, the Department of Health and Human Services announced it was extending the deadline for submitting 2014 enrollment counts for the transitional reinsurance contributions until 11:59 p.m. on December 5, 2014. the deadline was originally November 15, 2014.
On October 31, 2014, the Department of Health and Human Services announced it would not enforce the requirement to obtain a HIPAA Health Plan Identifier (HPID) until further notice. This enforcement delay applies to all HIPAA covered entities, including healthcare providers, health plans, and healthcare clearinghouses. The deadline to obtain an HPID was originally November 5, 2014.
Health plans face two deadlines between Halloween and Thanksgiving this year. One applies to all health plans with $5 million or more in annual claims; the other applies to all health plans and involves registering to make mandatory transitional reinsurance payments under the Affordable Care Act (ACA). One hits November 5, 2014 and the other on November 15. Are you prepared?
First deadline – November 5, 2014
The ACA and the Health Insurance Portability and Accountability Act (HIPAA) together require health plans and health care providers to obtain unique 10-digit Health Plan Identifiers (HPIDs). This is intended to standardize electronic transactions within the overall health care delivery and payment system. The HPID application for self-funded health plans with $5 million or more in annual claims is due by November 5, 2014. Self-funded plans with less than $5 million in claims last year can wait another year, until November 5, 2015, to apply for their HPID. Health insurance companies for fully insured plans are responsible for obtaining or have already obtained HPIDs, so fully insured plan sponsors shouldn’t need to worry about this requirement.
Word heard from other benefits professionals: The application process is full of red tape, but the start-to-finish time has shortened quite a bit from the months-long process experienced by some this summer. However, it still takes more than one day—It is a multistep process that involves logging off and waiting for e-mails from the government before proceeding to the next step. The shortest application time reported so far on the ISCEBSLink chat board was one week from start to finish. Other advice included using Chrome or Firefox, not Internet Explorer.
Someone at each organization will need to register as the “submitter” and someone else as the “authorizer” to go through the application process. (As I understand it, the submitter is the benefits professional undertaking the application process; the authorizer has official authority to authorize the submitter to do the work.)
Many are waiting and hoping the Department of Health and Human Services will eliminate this requirement for self-funded health plans, because it doesn’t seem to make a lot of sense for them. However, HHS had not done so at the time of this writing.Resources:
CMS “quick” reference guide to applying for HPID
CMS FAQs
Second deadline – November 15, 2014
ACA imposes a Transitional Reinsurance Fee on self-funded and insured plans providing major medical coverage in 2014, 2015 and 2106. To facilitate payment of this fee, health insurers, self-funded plans, and third-party administrators (TPAs) must register on www.Pay.gov and complete an ACA Transitional Reinsurance Program Annual Enrollment and Contributions Submission Form no later than November 15, 2014. Information required on the form includes the number of individuals the plan covers, the plan’s bank account information and a date for scheduled electronic withdrawal from the bank account on or before January 15, 2015.
The initial payment of $52.50 per covered individual is due January 15, 2015. A second payment of $10.50 per covered individual is due November 15, 2015. A plan may instead pay the total amount of $63.00 per covered individual by January 15, 2014.
Both fully insured and self-funded health plans are subject to reinsurance fees. Insured plans rely on the insurer to file and pay the fee. If the plan is self-funded, the plan is responsible for registering and making the payment. However, if the self-funded plan is administered by a TPA, the TPA might register and transfer payments on the self-funded plan’s behalf. The plan would need to negotiate these arrangements with the TPA.
Resources:
ACA Transitional Reinsurance Form on Pay.gov
Patient Protection and Affordable Care Act; HHS Notice of Benefit and Payment Parameters for 2015; Final Rule, Federal Register, March 11, 2014.
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