ACA Fees and Taxes Overview

ACA Fee Name(s) / Overview/Provision / Group Type / Amount/Calculation / Employer Impact / BCBSNC Impact / Supporting
Documents
Comparative Effectiveness Research Fee (PCORI) / The period during which the tax must be paid: for calendar year plans, years 2012-2018,for non-calendar year plans, plan years ending on or after 10/1/12 and before 10/1/19 to fund research on treatments and RX / Fully-insured and ASO / $1 PMPY 2012
$2 PMPY 2013
Indexed to CPI-M 2014+ / Self-insured employers pay per regulation
Rule explicitly states that third party administrators are not permitted to pay or report the tax on behalf of self-funded plans / Included in fully-insured rates /
Employer Shared Responsibility (Pay or Play Provision) / If a large employer chooses not to offer coverage or if the coverage does not meet criteria, a penalty will be imposed beginning in 2014 / Large (50 or more FTEs) fully-insured and ASO / If no coverage offered - $2,000 x (FTE – 30)
If coverage doesn’t meet criteria, the penalty is the lesser of $3,000 x FTEs drawing tax credit OR $2,000 x FTEs / Employer is fully responsible for paying penalties / No impact /
Health Insurer Tax / A tax on health insurers based on the insurer’s total market share of applicable premiums, beginning in 2014 / Fully-insured / 2014: About 2.3-2.9% of premium
2015: About 2.5-3.5% of premium / Built into rates / Fully insured pro-rata in 2013; full amount built in rates 1/1/14 and after
High Value Plan (Cadillac Plans) Tax / Excise tax imposed on total annual value of employer-sponsored coverage that exceeds $10,200/single, $27,500/family (value includes employer, employee contributions), beginning in 2018 / Fully-insured and ASO / 40% tax on coverage that exceeds 10,200/single and 27,500/family / Non-deductible tax paid through increased premiums for fully-insured or through a surcharge for an ASO
Risk Adjustment Program / Permanent program to transfer funds from lower risk to higher risk plans, beginning in 2014 / Non-grandfathered plans in/out of Exchange in individual and small group markets / Baseline premium x plan average
actuarial risk = Risk adjustment
payments/charges
*Formula set for 1st year by HHS, alternative formulas may be allowed in future years
(Note: HHS also plans to collect a risk adjustment user fee (estimated to be no more than $1 per enrollee/year) to cover the cost of the administration of the risk adjustment program. The user fee would be offset against any charges/payments made under the risk adjustment program) /
Risk Corridor Program / Temporary program designed to limit issuer losses and gains; effective from 2014-2016 / Qualified health plans in individual and small group markets / If issuer's allowable costs are less than 97 percent of its target amount, the issuer pays HHS a percentage of the difference, OR
If issuer’s allowable costs are more than 103 percent, HHS pays issuer a percentage of the difference /
Transitional Reinsurance Program Fee
(TRP) / Annual fee to fund temporary reinsurance program 2014-2016 / Fully-insured and ASO / 2014: $63 PMPY HHS PROPOSED estimate) / Self-insured employers pay per regulation; Fully insured employers will have amount built into rates. / Fully-insured pro-rata in 2013; full amount built in rates /

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