Issued by: Centers for Medicare & Medicaid Services (CMS)

Issue Date: October 07, 2014

Program Area: Reinsurance-Contributions (RIC)

Question: Please clarify whether the plan sponsor of a self-insured plan (the Contributing Entity) which changes Third Party Administrators (TPAs) during the first three (3) quarters of the year can have each TPA submit the ACA Transitional Reinsurance Program Annual Enrollment and Contributions Submission Form (the Form) attesting to the annual member count during the portion of the first three (3) quarters the TPA administered the plan or should issuers only submit one (1) Form if the plan was self-insured for the entire period?

Answer: Applicable to All Reinsurance Contributions Benefit Years: The ultimate responsibility to make reinsurance contributions lies with the Contributing Entity, and the decision to delegate the function of submitting the reinsurance contribution is with the Contributing Entity. However, only one (1) Reporting Entity should file the ACA Transitional Reinsurance Program Annual Enrollment and Contributions Submission Form and Supporting Documentation (.CSV file), if applicable per Contributing Entity; therefore, both TPAs would not be able to report for the same Contributing Entity only covering a portion of the benefit year because the submission must reflect the entire benefit year.

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