Employers and other self-insured group health plan sponsors and health insurers, adjust your budgets and prepare to open up your wallets to pay additional fees mandated by the Patient Protection and Affordable Care Act (“PPACA”).
Self-insured employers and health insurers generally must begin paying a new fee imposed as part of PPACA. PPACA generally requires that health insurance policy issuers and plan sponsors of self-insured health plans pay the new fee for policy and plan years ending on or after October 1, 2012, and before October 1, 2019 or policy and plan years ending on or after October 1, 2012, and before October 1, 2019. July 31, 2013 is the deadline for reporting and payment of the first fee payment required by these provisions.
The Internal Revenue Service (IRS) and Department of Treasury published final regulations (“Regulations”) implementing these new rules on December 6, 2012. These Regulations include many provisions that are likely to come as a surprise to many employer and other health plan sponsors. Health insurers, employers and other sponsors of self-insured health plans and others responsible for their funding and administration need to review these regulations and make other arrangements to budget for and timely report and pay this required fee.
New Fees Help Fund New Patient-Centered Outcomes Research Institute
PPACA amended the Internal Revenue Code (“Code”) to require the new fee to help fund the establishment and operation of the new Patient-Centered Outcomes Research Institute (the ‘‘Institute’’) to be created by PPACA. Congress intends that the Institute will be a private, nonprofit corporation charged with conducting research to help assist patients, clinicians, purchasers, and policy-makers in making informed health decisions by advancing the quality and relevance of evidence-based medicine through the synthesis and dissemination of comparative clinical effectiveness research findings.
PPACA added new Sections 4375, 4376, and 4377 to the Code to provide a funding source for the Trust Fund. These new Code Sections impose require issuers of specified health insurance policies and plan sponsors of applicable self-insured health plans to pay the new fee by July 31, 2012 for each plan year beginning after September 30, 2012 and before October 1, 2019 to fund the Patient-Centered Outcomes Research Trust Fund (the “Trust Fund”), which in turn will help pay the costs of the Institute.
Code Section 4377(c) provides that the fees imposed by sections 4375 and 4376 are treated as taxes for purposes of subtitle F of the Code (sections 6001 through 7874 that set forth the rules of federal tax procedure and administration).
Fee Amount Calculation & Payment
As amended by PPACA, the Code requires that employers sponsoring self-insured group health plans and most health insurers file a return and pay a fee equal to $1 multiplied by the average number of lives covered under the plan or policy by July 31, 2012. The amount of this fee will increase to $2 multiplied by the average number of lives for post-September 30, 2013 plan years. For post-September 30, 2014 plan years, the Code provides for further adjustments in the fee based on increases in the projected per capita amount of National Health Expenditures.
To meet this requirement, health insurers and plan sponsors must file a Form 720, Quarterly Federal Excise Tax Return along with the required payment once a year on or before July 31 of the calendar year following the last day of the policy year or plan year for which the fee is required to report and pay the fee.
Overview of ACA Rules Requiring Payment of Fee
The Code now separately assesses a fee on issuers of health insurance policies and on plan sponsors of self-insured health plans for each policy year ending on or after October 1, 2012 and before October 1, 2019. Code Section 4375 requires payment of a fee by “issuers” of “specified health insurance policies.” Code Section 4376 requires “sponsors” of self-insured health plans to pay a fee.
Each of these Code Sections basically uses the same formula to calculate the required fee owing by a health insurance issuer or a self-insured plan sponsor. The amount of the required fee due on July 31, 2013 for plan years beginning on or before October 1, 2013 will be one dollar multiplied by the average number of lives covered by the policy or plan. The fee due on July 31, 2014 for plan years beginning between October 2, 2013 and October 1, 2014 is set to increase to two dollars multiplied by the average number of lives covered under the policy. For policy or plan years ending on or after October 1, 2014, PPACA provides for additional increases in the required fee based on increases in the projected per capita amount of National Health Expenditures. See Treas. Reg. §§ 46.4375–1; Rejecting arguments that Congress only intended to require that either the insurer or the plan sponsor pay a fee annually, the Regulations construe these requirements as obligating both a self-insured health plans sponsor and an insurer to pay a separate fee annually, even if the fee is assessed upon the same lives.
The Preamble to the Regulations states that a self-insured plan sponsor must pay the fee with respect to arrangements where the plan design layers a self-insured portion of the plan with an insured portion, even though the insurer also must pay the fee with respect to the insured portion.
The fee calculation differs slightly for purposes of determining the fee a self-insured plan sponsor owes versus the fee owed by an insurer. Regardless, however, the Regulations state that for purposes of calculating these numbers, retirees and beneficiaries continuing coverage under the group medical coverage continuation rules generally count. The Preamble to the Regulations states that the IRS views retiree-only plans and COBRA coverage subject to the tax imposed under Code § 4375 and plan sponsors may be required to pay the tax under Code § 4376. Concerning retiree-only coverage, the Preamble states:
- Although group health plans that have fewer than two participants who are current employees (such as retiree-only plans) are excluded from the requirements of Code chapter 100 (setting forth requirements applicable to group health plans such as portability, nondiscrimination, and market reform requirements), this exclusion does not apply to Code §§ 4375 and 4376 because these sections are in chapter 34; and
- For self-insured arrangements, Code § 4376(c)(2)(A) states explicitly that an applicable self-insured health plan includes a plan established or maintained by one or more employers for the benefit of their employees or former employees.
Section 4376 Fee For Self-Insured Plan Sponsors
Applicability of Code Section 4376 Fee To Self-Insured Health Plans. The fee under Code Section 4376 applies to the plan sponsor of an applicable self-insured health plan.
Section 4376(c) defines an applicable self-insured health plan as any plan for providing accident or health coverage if any portion of the coverage is provided other than through an insurance policy, and the plan is established or maintained by either:
- One or more employers for the benefit of their employees or former employees;
- One or more employee organizations for the benefit of their members or former members;
- Jointly by one or more employers and one or more employee organizations for the benefit of employees or former employees;
- By a voluntary employees’ beneficiary association described in Code Section 501(c)(9); or
- By any organization described in section 501(c)(6), or (6) if not previously described, by a multiple employer welfare arrangement (as defined in section 3(40) of the Employee Retirement Income Security Act (“ERISA”), a rural electric cooperative under ERISA Section 3(40)(B)(iv), or a rural telephone cooperative association under ERISA Section 3(40)(B)(v). See Code § 4376; Regulation §46.4376–1(a), (b)(1).
Code Section 4376(b)(1) requires that the plan sponsor of a self-insured health plan pay the required fee for self-insured health plans imposed by Section 4376(a). For this purpose, Code Section 4376(b)(2) defines a plan sponsor as:
- The employer in the case of a plan established or maintained by a single employer;
- The employee organization in the case of a plan established or maintained by an employee organization;
- The association, committee, joint board of trustees, or other similar group of representatives of the parties who establish or maintain the plan in the case of: (1) a plan established or maintained by two or more employers or jointly by one or more employers and one or more employee organizations; (2) a multiple employer welfare arrangement; or (3) a voluntary employees’ beneficiary association described in Code Section 501(c)(9); or
- The cooperative or association that establishes the plan in the case of a plan established or maintained by a rural electric cooperative or rural telephone cooperative association within the meaning of ERISA.
Regulation § 46.4376-2(b)(2) defines plan sponsor to mean the following:
- The employer for a self-insured health plan established or maintained by a single employer;
- The employee organization for a self-insured health plan established or maintained by an employee organization;
- The joint board of trustees for a multiemployer plan within the meaning of Code §414(f));
- The committee, in the case of a multiple employer welfare arrangement within the meaning of Section 3(40) of the Employee Retirement Income Security Act (“ERISA”);
- The cooperative or association that establishes or maintains an applicable self-insured health plan established or maintained by a rural electric cooperative under ERISA § 3(40)(B)(iv) or rural cooperative association under ERISA 3(40)(B)(v);
- The trustee, in the case of an applicable self-insured health plan established or maintained by a voluntary employees’ beneficiary association under Code § 501(c)(9) not merely serving as a funding vehicle for a plan that is established or maintained by an employer or other person;
- In the case of an applicable self-insured health plan the plan sponsor of which is not previously described, the person identified by the terms of the document under which the plan is operated as the plan sponsor, or the person designated by the terms of the document under which the plan is operated as the plan sponsor for Code § 4376 purposes, provided that designation is made in writing, and that person has consented to the designation in writing, by no later than the date by which the return paying the fee under section 4376 for that plan year is required to be filed, after which date that designation for that plan year may not be changed or revoked, and provided further that a person may be designated as the plan sponsor only if the person is one of the persons establishing or maintaining the plan (for example, one of the employers that establishes or maintains the plan with one or more other employers or employee organizations); or
- Where an applicable self-insured health plan sponsor is not previously and for which no identification or designation of a plan sponsor has been made under the prior paragraph the plan sponsor means, each employer that establishes or maintains the plan with respect to employees of that employer, each employee organization that establishes or maintains the plan with respect to members of that employee organization, and each board of trustees, cooperative, or association that establishes or maintains the plan.
While the fee will impact most health insurance policies and self-insured plans, the Code does exempt a few arrangements. See Code § 4376. Regulation § 46.4376-1(b)(2) construes these exemptions to include the following categories of programs:
- A plan that provides benefits substantially all of which are excepted benefits for purposes of the HIPAA Portability Rules under Code § 9832(c). Pursuant to this provision, for instance, the Regulations state that a health flexible spending arrangement (health FSA) under Code § 106(c)(2)) that satisfies the requirements to be treated as an excepted benefit under Code § 9832(c) and Regulation § 54.9831–1(c)(3)(v) is not an applicable self-insured health plan. However, a health FSA that is not treated as an excepted benefit under Code § 9832(c) and Regulation § 54.9831–1(c)(3)(v) is an applicable self-insured health plan.
- An employee assistance program, disease management program, or wellness program if the program does not provide significant benefits in the nature of medical care or treatment.
- A plan that, as demonstrated by the facts and circumstances surrounding the adoption and operation of the plan, was designed specifically to cover primarily employees who are working and residing outside the United States (as defined in § 46.4377–1(a)(3)). See Regulation § 46.4376–1(b)(ii).
Where the same plan sponsor maintains multiple self-insured arrangements Regulation § 46.4376(b)(iii) specifies that the employer may treat two or more arrangements established or maintained by the same plan sponsor that provide accident and health coverage other than through an insurance policy and that have the same plan year as a single applicable self-insured health plan for purposes of reporting and calculating the Code § 4376 fee.
Calculation Of Self-Insured Plan Fee Under Code § 4376
Regulation § 46.4376-1 requires that a self-insured plan sponsor determine the number of covered lives for purposes of calculating the fee using on of the following methods:
- The actual count method where the plan sponsor adds the totals of lives covered for each day of the plan year and divides that total by the number of days in the plan year;
- The snapshot method, the plan sponsor adds the totals of lives covered on a date during the first, second, or third month of each quarter of the plan year (or more dates in each quarter if an equal number of dates is used in each quarter), and divides that total by the number of dates on which a count was made in accordance with rules set forth in the Regulations. For instance, Each date used for the second, third and fourth quarter must be within three days of the date in that quarter that corresponds to the date used for the first quarter, and all dates used must fall within the same plan year. If a plan sponsor uses multiple dates for the first quarter, the plan sponsor must use dates in the second, third, and fourth quarters that correspond to each of the dates used for the first quarter or are within three days of such corresponding dates, and all dates used must fall within the same plan year. The 30th and 31st day of a month are treated as the last day of the month for purposes of determining the corresponding date for any month that has fewer than 31 days. The number of lives covered on a designated date using this method may be determined using either the snapshot factor method or the snapshot count method set forth in the Regulations. In the snapshot factor method, the number of lives covered on a date is equal to the sum of: (1) the number of participants with self-only coverage on that date; plus (2) the number of participants with coverage other than self-only coverage on the date multiplied by 2.35. In the snapshot count method, the number of lives covered on a date equals the actual number of lives covered on the designated date. The plan sponsor must use the same method of calculating the average number of lives covered under the plan consistently for the duration of the plan year. However, a plan sponsor may use a different method from one plan year to the next.
- The Form 5500 method, where the plan sponsor determines the average number of lives covered under a plan for a plan year as the result of the sum of the total participants covered at the beginning and the end of the plan year, as reported on the Form 5500 or Form 5500–SF for the applicable self-insured health plan, divided by 2. This method is only available if the Form 5500 is filed by the due date for payment of the fee. This means where a plan administrator extends filing beyond July 31, the plan sponsor cannot use this method.
The Regulations establish a special rule for lives covered solely by the fully-insured options under an applicable self-insured health plan. Under this special rule, when an applicable self-insured health plan provides accident and health coverage through fully insured options and self-insured options, the plan sponsor is permitted to disregard the lives that are covered solely under the fully-insured options in determining the lives covered taken into account for the actual count method, the snapshot method, and the Form 5500 method.
As for insured plans, the Regulations also provide special rules for determining the fee the first year the fee is in effect. Under this rule, for a plan year beginning before July 11, 2012, and ending on or after October 1, 2012, a plan sponsor may determine the average number of lives covered under the plan for the plan year using any reasonable method.
Section 4375 Fee For Insurers
The fee under Code Section 4375 generally applies to issuers of a “specified health insurance policy.” Code Section 4375(c) generally defines a specified health insurance policy as any accident or health insurance policy (including a policy under a group health plan) issued with respect to individuals residing in the United States. Code Section 4377(a)(1) defines accident and health coverage as any coverage that, if provided by an insurance policy, would cause the policy to be a specified health insurance policy under Code Section 4375. See Treas. Reg. § 46.4375–1.
Policies Subject To Fee. Regulation § 46.4377–1(a) defines a “specified health insurance policy” as “any accident and health insurance policy (including a policy under a group health plan) issued with respect to individuals residing in the United States” other than those recognized as exempt by the Regulation. The Regulation makes clear that this includes any policy that provides accident and health coverage to an active employee, former employee, or qualifying beneficiary, as continuation coverage required under the Consolidated Omnibus Budget Reconciliation Act of 1985 (COBRA) or similar continuation coverage under other Federal law or state law.
However Regulation § 46.4377-1(a)(ii) exempts the following arrangements from the definition of a specified health insurance policy.
- Any insurance policy if substantially all of its coverage is of excepted benefits described in Code Section 9832(c);
- Any group policy issued to an employer where the facts and circumstances show that the group policy was designed and issued specifically to cover primarily employees who are working and residing outside of the United States for purposes of Regulation § 46.4377–1(a)(3);
- Any stop loss or indemnity reinsurance policy; or
- Any insurance policy to the extent it provides an employee assistance program, disease management program, or wellness program if the program does not provide significant benefits in the nature of medical care or treatment.
Fee Calculation. The amount of the fee an insurer must pay for a policy for a policy year under Code § 4375 is equal to the product of the average number of lives covered under the policy for the policy year, multiplied by the applicable dollar amount for that policy year.
The applicable dollar amount multiplier is $1 for the fee due on October 1, 2013; $2 for the fee due on October 1, 2014, and the adjusted amount for fees due after October 1, 2014.
Determination Of The Average Number Of Lives Covered. To determine the average number of lives covered under a specified health insurance policy during a policy year, the Regulation requires an issuer to use one of the following methods:
- The actual count method, where the issuer determines the average number of lives covered under a policy for a policy year under the actual count method by adding the total number of lives covered for each day of the policy year and dividing that total by the number of days in the policy year;
- The snapshot method, where the issuer determines the average number of lives covered under a policy for a policy year by adding the totals of lives covered on a date during the first, second, or third month of each quarter (or more dates in each quarter if an equal number of dates is used for each quarter), and dividing that total by the number of dates on which a count is made. Each date used for the second, third and fourth quarters must be within three days of the date in that quarter that corresponds to the date used for the first quarter, and all dates used must be within the same policy year. If an issuer uses multiple dates for the first quarter, the issuer must use dates in the second, third, and fourth quarters that correspond to each of the dates used for the first quarter or are within three days of such corresponding dates, and all dates used must be within the same policy year. The 30th and 31st day of a month are treated as the last day of the month for purposes of determining the corresponding date for any month that has fewer than 31 days (for example, if either March 30 or March 31 is used as a counting date for a calendar year policy, June 30 is the corresponding date for the second quarter);
- The member months method, where the issuer determines the average number of lives covered under all policies in effect for a calendar year based on the member months (an amount that equals the sum of the totals of lives covered on prespecified days in each month of the reporting period) reported on the National Association of Insurance Commissioners (“NAIC”) Supplemental Health Care Exhibit filed for that calendar year. Under this method, the average number of lives covered under the policies in effect for the calendar year equals the member months divided by 12; or
- The state form method, where an insurer not required to file NAIC annual financial statements may determine the number of lives covered under all policies in effect for the calendar year using a form filed with the issuer’s state of domicile and a method similar to the member months method if the form reports the number of lives covered in the same manner as member months are reported on the NAIC Supplemental Health Care Exhibit. See Regulation § 46.4375–1(c)(2)(i).
Issuers must use the same method of calculating the average number of lives covered under a policy consistently for the duration of the year and must use the same method of computing lives for all policies for which a liability is reported on a Form 720, “Quarterly Federal Excise Tax Return,” for a particular year. Regulation § 46.4375–1(c)(2)(ii). However, the Regulation allows an issuer that determines the average number of lives covered by using the actual count method or the snapshot method to change its method of computing the average lives covered to the snapshot method or actual count method, respectively, provided that the issuer uses the same method for computing the average lives covered for all policies for which a liability is reported on the Form 720 for that year. Regulation § 46.4375–1(c)(2).
The Regulations also impose various other special rules. For instance, the Regulations state that if the issuer elects to determine the average number of lives covered for all policies in effect during a calendar year using the member months method or the state form method, the applicable dollar amount with respect to such issuer’s policies for such calendar year is the applicable dollar amount for policy years ending on December 31 of such calendar year, except that the applicable dollar amount with respect to such an issuer’s policies for calendar year 2019 is the applicable dollar amount for policy years ending on September 30, 2019. The Regulations provide various examples of these calculations to illustrate the rules.
The Regulations also provide special rules for the first year and the last year the fee is in effect for an insurer. See Regulation § § 46.4375–1(c).
Plans, Insurers Should Evaluate Options, Plan To Pay Required Fees
The impending obligation provides yet another reason that employers and other self-insured plan sponsors, administrators, insurers, and vendors should re-evaluate their existing health plan designs and costs. Most health insurers and self-insured health plan sponsors will want not only to budget for the impending additional costs associated with these fees, but also evaluate options for mitigating their impact, as well as the costs and administrative burden of tracking and making the required filings. For instance, insurers and plan sponsors of programs subject to these new fees generally will want to evaluate which of the options for collecting the data and calculating the fees will most benefit them. Also, where plan designs used by particular employer or other plan sponsors include both insured and self-insured features, the insurer, plan sponsor and their advisors may want to consider the advisability of restructuring or redesigning plans to mitigate fees or administrative or other expenses. In all cases, parties should audit their programs to ensure that each program and its element is identified and properly taken into account to avoid inadvertent oversights resulting in penalties or other avoidable costs.
For Help With Compliance, Risk Management, Investigations, Policy Updates Or Other Needs
If you need help with these or other health benefit or other human resources, employee benefit, insurance, compensation or other compliance, risk management, enforcement or management concerns, the author of this update, attorney Cynthia Marcotte Stamer may be able to help.
A Fellow in the American College of Employee Benefit Counsel, State Bar of Texas and American Bar Association, Vice President of the North Texas Health Care Compliance Professionals Association, the Former Chair of the ABA RPTE Employee Benefit & Compensation Group and current Co-Chair of its Welfare Benefit Committee, Vice Chair of the ABA TIPS Employee Benefit Committee, an ABA Joint Committee on Employee Benefits Council Representative, and Past Chair of the ABA Health Law Section Managed Care & Insurance Section, Ms. Stamer is nationally and internationally recognized for her experience and skill aiding clients with a diverse range of employment, employee benefits, health and safety, public policy, and other compliance and risk management concerns.
Board Certified in Labor & Employment Law by the Texas Board of Legal Specialization, a member of the Editorial Advisory Board and expert panels of HR.com, Employee Benefit News, InsuranceThoughtLeadership.com, and Solutions Law Press, Inc., management attorney and consultant Ms. Stamer has 25 years of leading edge experience helping employers; health and other employee benefit plans and their sponsors, administrators, fiduciaries; TPAs, insurers, governments, employee leasing, recruiting, staffing and other professional employment organizations; and others design, administer and defend innovative workforce, compensation, employee benefit and management policies and practices. Her experience includes extensive work representing advising these and other clients, governmental bodies, insurance and financial services organizations, third party administrators and others to develop, design, defend and administer creative health, disability, severance and other employee benefit and compensation arrangements, products and services. She also helps these and other clients monitor, address and respond to federal, state, and international health care and insurance and other regulatory, legislative, audit and enforcement developments. Ms. Stamer has worked, extensively on these and other workforce and performance related matters. In addition to her continuous day-to-day involvement helping businesses to manage employment and employee benefit plan concerns, she also has extensive public policy and regulatory experience with these and other matters domestically and internationally. A former member of the Executive Committee of the Texas Association of Business and past Government Affairs Committee Legislative Chair for the Dallas Human Resources Management Association, Ms. Stamer served as a primary advisor to the Government of Bolivia on its pension privatization law, and has been intimately involved in federal, state, and international workforce, health care, pension and social security, tax, education, immigration, education and other legislative and regulatory reform in the US and abroad. She also is recognized for her publications, industry leadership, workshops and presentations on these and other human resources concerns and regularly speaks and conducts training on these matters. Her insights on these and other matters appear in the Bureau of National Affairs, Spencer Publications, the Wall Street Journal, the Dallas Business Journal, the Houston Business Journal, and many other national and local publications. For more information about Ms. Stamer and her experience or to get access to other publications by Ms. Stamer see here or contact Ms. Stamer directly. Ms. Stamer regularly works with agencies, publishes and speaks extensively on human resources and employee benefits, medical and other privacy and data security, health and managed care industry regulatory, staffing and human resources, compensation and benefits, technology, public policy, reimbursement and other operations and risk management concerns. Her publications and insights on HIPAA and other data privacy and security concerns appear in the Health Care Compliance Association, Atlantic Information Service, Bureau of National Affairs, World At Work, The Wall Street Journal, Business Insurance, the Dallas Morning News, Modern Health Care, Managed Healthcare, Health Leaders, and a many other national and local publications. You can get more information about her HIPAA and other experience here.
If you need help with these or other compliance concerns, wish to ask about arranging for compliance audit or training, or need legal representation on other matters please contact Ms. Stamer at (469) 767-8872 or via e-mail here.
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