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New Reinsurance Fee Under the ACA
McGladrey 
[Guidance Overview] Sept. 26, 2014
"A plan sponsor of a self-insured plan may use any of ... four methods to determine the number of covered lives in the plan for the nine-month period of Jan. 1 through Sept. 30. Plan sponsors must use only one method for any calendar year; however, they are not required to use the same method from one year to the next and do not need to use the same method for calculating the reinsurance fee and the PCOR fee. Since the different counting methods can produce different results, it is advisable for an employer to do the computations under more than one method to determine which one produces the lowest fee."
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