The ACA is Not Gone Yet! MLR Rebate Filings Still Due in July

Submitted by Cynthia Braman on Fri, 06/09/2017 - 2:53pm

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By Bruce Darling

Trying to keep up with the MLR filingsWhile the world watches the “Repeal and Replace” whirlwind in Washington, those of us in the Health industry are still dealing with business as usual relative to many ACA programs. In particular, 2016 plan year Medical Loss Ratio (MLR) rebate calculation forms are still due by July 31 this year.

MLR rebates have been one of the more successful provisions of the ACA, at least from a consumer value perspective. Total rebates for the first five years of the program have totaled nearly $2.8 billion.

Also, for the most recent plan year, 2015, only 4% of large group members, 7% of small group members, and 13% of individual plan members are enrolled in plans that fail to meet the minimum 80 or 85% MLR thresholds. By way of comparison, those percentages were 11%, 17%, and 38% in 2011, the first year of the MLR program.

For preparers of the MLR and rebate filing, however, the process has become more and more complex. While a fair number of input amounts such as member month exposures, expenses, and taxes may be pulled from the NAIC Supplemental Health Care Exhibit that precedes the actual MLR work by several months, a significant number of inputs must be developed and adjustments made just for the MLR forms.

These include:

  • Revaluing incurred benefits with an additional quarter of hindsight
  • Deferring numerator and denominator amounts related to new business to the following MLR year when experience is more complete
  • Combining multiple years of exposure with retrospective adjustments to the prior years
  • Incorporating reporting for the “3 Rs” – the ACA risk adjustment, reinsurance, and risk corridor programs.

Meanwhile, Congress has done its share to make things more suspenseful by putting off and ultimately failing to fund ACA promises such as paying risk corridor payments in excess of contributions and cost-reduction subsidies – making valuation of related receivables something of an ordeal.

For several years now, around this time of year, Booke has presented a trio of health webinars for the benefit of those who prepare or are otherwise interested in the MLR filing process.

This trio consists of:

  • A refresher on the Statutory reporting implications of ACA programs
  • A comprehensive look at the NAIC Supplemental Health Care Exhibit that produces not only a preliminary MLR but also provides a fair number of input items for the actual MLR filing
  • A comprehensive preparer’s guide to the MLR and Rebate calculation forms.


We’ll be offering the trio twice this year, first June 27, 29-30, and then, July 11, 13-14. Read more about the webinars