Under health care reform, plan sponsors of self-funded health plans and health insurance issuers will owe a new fee that is first payable for plan years ending after September 30, 2012. For calendar year plans this means the fee applies this year.
Many questions about the fee are currently unanswered, including when it must be paid. Proposed regulations are expected on this and other matters. In the meantime, Notice 2011-35 provides information for plan sponsors and issuers to ensure they have properly budgeted for this expense.