Reinsurance-Contributions (RIC) FAQ
Guidance for FAQ regarding Calculation / Methodology and Other
Program Area: Reinsurance-Contributions (RIC)
Question: How should the Annual Enrollment Count be calculated when a non-calendar-year group health plan that offers only one (1) coverage option changes from self-funded to fully insured mid-calendar year?
Answer: Applicable to All Reinsurance Contributions Benefit Years: If coverage changes from a fully insured plan to a self-insured plan or self-insured to fully insured during the first nine (9) months of 2014, the issuer of the fully insured plan is responsible for paying the per covered life contribution amount for reinsurance contribution enrollees for the portion of the calendar year they are enrolled in the fully insured plan. The self-insured plan is responsible for paying the per covered life contribution amount for reinsurance contribution enrollees for the portion of the year they are enrolled in the self-insured plan. Therefore, both plans are responsible for paying a portion of the fee for the year in which the change is made on behalf of the covered lives in those plans using one (1) of the permitted counting methods in 45 CFR 153.405(d) and 45 CFR 153.405(e) as applicable. These counting methods generally calculate covered lives based on enrollment in the first nine (9) months of a calendar year. If a plan or coverage is established or terminated during the first nine (9) months of 2015, then the Contributing Entity must select a set of counting dates for the nine (9)-month period in which had enrollees on each of the dates, if possible. For examples of how to calculate reinsurance contributions in these situations, please refer to "The Transitional Reinsurance Program Operational Guidance: Examples of Counting Methods for Contributing Entities" for the applicable benefit year.
Issued by: Centers for Medicare & Medicaid Services (CMS)
Issue Date: July 10, 2014
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