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The PPACA, or ACA or ObamaCare or whatever you want to call it is a very complicated law, over 1,200 pages of legislation with many more of regulatory interpretations and procedures. Naturally things get missed in summaries or in news reports. Here are two things that have generally been missed.
There are two fees that will have to be paid to support aspects of the ACA that most are not aware of. The first of these is a fee to support an organization called the Patient-Centered Outcomes Research Institute (PCORI). This was established to assist patients and policymakers in making informed health decisions through the dissemination of clinical research findings. Well someone has to pay for that organization and its work. According to a Seyfarth Shaw bulletin “Issuers of specified health insurance policies and plan sponsors of ‘applicable self-insured health plans’ are liable for PCORI fees. A plan is an applicable self-insured health plan if it is fully or partially self-funded. “But because insurers are paying the fee it is a sure bet that employers will in some way shape or form end up paying this fee.
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The fee is determined by multiplying the average number of covered lives for the plan year times $1 in the year 2013 and $2 for the second year, 2014. Fees after that will be readjusted as needed. Fees are due each July 31st.
The second fee under the Affordable Healthcare Act is for something called the Transitional Reinsurance Program (TRP). This is a fee to prop up the Exchanges in the transition period of three years it takes to get them running “smoothly.” This fee is paid by the same group of people and is also based on covered lives. But in this case covered lives include employees, spouses, dependents and any other individuals, such as domestic partners, receiving coverage. The fee is a hefty one! It is $63 per covered life. This starts in 2014 and must be paid by December 31, 2014 and then again in 2015 and 2016. So if you are self-insured do that math and start putting money aside.
I have glossed over much of this, but for a complete analysis feel free to read up on the Seyfarth Shaw Bulletin.
For more information on the Affordable Care Act visit our on-demand webinar, Cutting Through the Noise on the Affordable Care Act. You may be eligible for1 HRCI credit for registering and viewing.