On October 30, 2013, Health and Human Services ("HHS") released a regulation addressing reinsurance contributions by self-funded and self-administered plans. The regulation states that HHS intend to propose future rulemaking to exempt certain self-insured, self-administered plans from the requirement to make reinsurance contributions for the 2015 and 2016 years. According to the regulation, these employers would still be subject to the reinsurance fee for the 2014 benefits year. We are waiting for further clarification from HHS to clarify the exemption.

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