Transitional Reinsurance Program
The ACA's transitional reinsurance program (Section 1341) ran from 2014 to 2016. The program required health plans to contribute to a reinsurance fund that subsidized individual market insurers for high-cost enrollees. The contribution rate was $63 per covered life in 2014, $44 in 2015, and $27 in 2016.
Program End
The transitional reinsurance program ended after 2016. No contributions are required for plan years beginning after December 31, 2016. Employers who have open compliance questions from the 2014–2016 period should consult with ERISA counsel.
Current Status
IQ Insight
The transitional reinsurance program is no longer operative. However, understanding its history is important for advisors who work with clients that have open compliance questions from the 2014–2016 period, or who are reviewing historical plan documents and filings. The PCORI fee, by contrast, is ongoing and requires annual attention.