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Health insurance issuers and self-insured group health plans offering major medical coverage are required to file their annual enrollment counts and schedule a transitional reinsurance program fee by December 5 (originally November 15).

Navigating health reform

Affordable Care Act’s November 15 Filing Deadline for Transitional Reinsurance Program Extended Until December 5

  • 10/28/2014

Update 11/17/2014: The deadline for the transitional reinsurance fee annual enrollment and contributions submission form was extended to December 5, 2014. Additional information can be found at the CMS website.

The Affordable Care Act established a transitional reinsurance program for the 2014, 2015, and 2016 benefit years. The program will collect contributions to fund reinsurance payments to issuers of non-grandfathered reinsurance-eligible individual market plans, the administrative costs of operating the reinsurance program, and the General Fund of the U.S. Treasury.

Health insurance issuers and certain self-insured group health plans offering major medical coverage are required to file their annual enrollment counts and schedule payment for the transitional reinsurance program fee by November 15, 2014. These requirements apply to all employers, including tax-exempt and governmental entities. For 2014, the fee is $63 per covered life. Usually, the fee for fully insured plans is paid by the insurance company, whereas the fee for self-insured plans is paid by the plan sponsor.

Calculating contributions

Contribution amounts are calculated by multiplying a contributing entity’s annual enrollment count by the annual per covered life contribution rate. Various methods can be used to determine the annual enrollment count, and the contributing entity may chose to use the lowest one. In general, the counting methods calculate covered lives based on enrollment in the first nine months of a calendar year (for example, January 1, 2014, to September 30, 2014).


Certain types of coverage do not require a contributing entity to make reinsurance contributions. The most common exemptions are:

  • A health reimbursement account (HRA) that is integrated with a self-insured group health plan or health insurance coverage
  • Health savings accounts (HSA)
  • Health flexible spending accounts (FSA)

How we can help

CliftonLarsonAllen advisors can answer questions about reinsurance payments. Our employee benefit group helps employers identify the components of their health plans that are subject to this fee, and determine the best method to assess the annual number of lives covered. Enrollment fees must be paid at