PPACA Transitional Reinsurance

[Guest Ira Hayes]

A self funded major medical plan subject to PPACA and ERISA covering 1,000 employees on average typically has 2,350 covered dependents for a total of 3,350 covered lives. Hence, the contribution payable to HHS for transitional reinsurance is $211,050 ($63-3,350)

One of the alternate Form 5500 methods allows the plan sponsor to add the beginning and ending Form 5500 participant counts.. Assuming they add to 2,000, the alternative contribution is only $126,000 ($63-2,000).

The resulting savings is $85,050 ($211,050 - $126,000). Is this a correct interpretation of the HHS final regulations published in the Federal Regiister on March 11, 2013?

Finally, who knows anything about a count reporting form to be made available at www.pay.gov for purposes of giving HHS the data needs to bill major medical plan sponsors?