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Health Care Reform: Fee Comparison Chart

Under the Affordable Care Act (ACA), a number of changes were implemented that affect health reimbursement arrangements (HRAs). To cover the cost of some of these changes, new fees have been imposed on health insurance issuers and sponsors of self-insured health plans. These fees include Patient-Centered Outcomes Research Institute fees (PCORI) and Reinsurance fees.

To help provide a clearer understanding of how these fees might impact your business, we’re happy to share the comparison chart below:

PCORI Fees

Reinsurance Fees

 
Applies To Health insurance issuers and sponsors of self-insured health plans Health insurance issuers and sponsors of self-insured group health plans

Effective Date Plan years ending on or after Oct. 1, 2012, and before Oct. 1, 2019. For calendar year plans, fees will be effective for the 2012 through 2018 plan years.The first possible payments will be due on July 31, 2013. Calendar years 2014 through 2016

Amount Calculated as follows:

  • $1 per covered life for plan years ending before Oct. 1, 2013
  • $2 per covered life for plan years ending on or after Oct. 1, 2013, and before Oct. 1, 2014
  • For plan years ending on or after Oct. 1, 2014, the fee amount will grow based on increases in the projected per capita amount of National Health Expenditures
Calculated for each issuer or plan sponsor using the following formula:

Average Number of Covered Lives multiplied by the National Contribution Rate

The national contribution rate will be announced by HHS annually. For 2014, HHS proposes a national contribution rate of $5.25 per month ($63 per year).


Special Rule for HSAs HRA Integrated with Self-insured Plan:

The HRA is not subject to a separate research fee, as long as the HRA and the plan:

  • Are established and maintained by the same plan sponsor; and
  • Have the same plan year.

HRA Integrated with Fully-insured Plan:

The plan sponsor of the HRA and the issuer of the insured plan will both be subject to the research fees, even though the HRA and insured group health plan are maintained by the same plan sponsor.

HRAs Integrated with Major Medical Coverage:

Excluded from reinsurance fees, regardless of whether the major medical coverage is self-insured or fully-insured.

Additional Information

I hope that you find this chart helpful as you seek to understand the impact of health care reform on your business.

For a more in-depth look at these fees and at the other components of the Affordable Care Act, I invite you to join us at a free seminar on March 21st.

The seminar will include a keynote presentation by Tom Greene and Patricia Moran of Mintz Levin. Their topic will be “Employer Responsibilities under Health Care Reform.”

RSVP today to reserve your seat!

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Posted in: Human Resources, Legislation

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