Important Deadline and Health Care Reform Update

The Health Care Reform landscape is constantly changing and evolving. The information below is meant to remind you of a Transitional Reinsurance Fee deadline on November 15 and instructions on Forms 1094-C, 1095-C, 1094-B, 1095-B, and 1095-A.

Important Deadline: Transitional Reinsurance Fee

Employers with self-funded plans need to be aware of and pay attention to the Transitional Reinsurance Fee and submit their enrollment count via to the Centers for Medicare & Medicaid Services by November 15, 2014. Following submission, employers will receive a bill for the amount owed, with the first payment of $52.50 per covered life due by January 15, 2015, and the second payment of $10.50 per covered life due by November 15, 2015.

Please note: HSAs, as well as HRAs that are integrated with a health plan, are not included in this fee.

Learn more about the Transitional Reinsurance Fee by clicking Centers for Medicare & Medicaid Services above.  Please note that you do not receive an actual invoice for are prompted with how much you owe upon completing the submission.


Update: Completion of Forms

On August 28, 2014, the IRS released draft instructions to Forms 1094-C, 1095-C, 1094-B, 1095-B and 1095-A. Although these are draft instructions, they offer good insight into the way the IRS will handle the filing requirement for employers, insurance carriers and the exchange.

Click here to read a brief summary for each form.

Please contact your Eide Bailly professional for additional information, visit our website or watch our Health Care Reform videos.

HIPAA HPID Requirements Will Not Be Enforced

The enforcement of the Health Plan Identifier (HPID) requirements will be delayed until further notice, according to the Centers for Medicare and Medicaid Service. This delay applies to all entities that are covered by HIPPA. The HPID is a “standard, unique identifier” of health plans required under HIPAA, and while employers may still go through the process to obtain an HPID, they may also wait to see how this delay pans out. An announcement from CMS explains in detail.

The Skinny on “Skinny Plans”

There has been a recent increase in popularity of so-called “skinny plans” by several insurance providers. These plans aim for the bare minimum, meeting value requirements for health insurance coverage but lacking in-patient hospitalization coverage. The IRS and HHS say this is NOT okay, and are planning to issue proposed regulations saying such plans MUST include coverage for in-patient hospitalization services in order to meet minimum value requirements. Under the same notice, it will be stated that employers who promote these “skinny plans” cannot use the online minimum value calculator, as it will not offer an accurate determination of minimum value under these plans. These regulations are set to be finalized in 2015 and will likely apply to plan years beginning on or after November 4, 2014, but will likely not apply to those who have already finalized plans prior to that date.

Contact Eide Bailly’s Employee Benefits team for additional information.