USI’s Compliance Team has summarized the recent guidance from Health and Human Services (HHS) and the IRS regarding fees, taxes and cost-sharing limits under the Affordable Care Act. The guidance provides clarification and updates on existing requirements and will likely reduce costs slightly.
Highlights of the HHS guidance include:
- An estimate that the Transitional Reinsurance Fee (TRF) will drop to $44 annually per covered life in 2015 – down from the $63 annual fee applicable in 2014.
- Confirmation that the TRF will apply to self-insured plans, except for a very small group of self-insured plans beginning in 2015 – those that are directly administered by the employer and not by an independent third party administrator or insurance company.
- Announcement that the out-of-pocket maximums applicable to non-grandfathered plans will increase for 2015 to $6,750 for self-only coverage and $13,500 for family coverage (coverage other than self-only) – up from $6,350/$12,700 in 2014.
The IRS guidance deals with the health insurer fee imposed on health insurers beginning in 2014 (scheduled at $8.3 billion for 2014). Among other things:
- It confirms that the fee applies to dental and vision coverages as well as medical, but not to EAP and wellness programs, unless they provide significant health insurance benefits.
- It confirms that stop loss coverage will not be subject to the fee, at least for now. There continues to be discussion inside the government agencies as to whether this fee should apply to stop loss.
We are working with carriers to ensure that this additional guidance is reflected in the financial analysis of clients’ programs, including any upcoming and subsequent renewals. To learn more about USI’s Compliance attorneys and due diligence on your behalf, contact our office at 212-842-3700.