Affordable Care Act’s Transitional Reinsurance Program

InsightsClient Alert

As mandated by the Affordable Care Act (ACA), health insurance issuers and self-funded group health plans are required to pay a reinsurance fee to the Transitional Reinsurance Program over the next three years, beginning with calendar year 2014. This fee is applicable to self-funded group health plans that meet minimum coverage requirements.

The amount of the reinsurance fee will be determined by the ACA Transitional Reinsurance Program Annual Enrollment and Contributions Submission Form, which is available at This form must be completed by November 15, 2014.

There are two options for fee payment: (1) full payment due January 15, 2015, or (2) two installments due January 15, 2015 and November 15, 2015. The fee is assessed on a per capita basis and will decrease each year. The fee schedule for the three years is as follows:

  • 2014 – $5.25/member/month or $63/member/year
  • 2015 – $3.67/member/month or $44/member/year
  • 2016 – not yet determined

The IRS has proposed four methods for determining member counts. The same method must be used for the entire calendar year. Counts must be based on the first nine months of the calendar year regardless of the plan year or renewal date and should only be submitted once a year.

If you have any questions, please contact our Albany office at (229) 883-7878 or our Atlanta office at (404) 220-8494.