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  Health Insurance Claims Assessment (HICA) Act
 

 
  General Information
  What is the Health Insurance Claims Assessment (HICA) Act?
  I received a notification letter from Treasury, but do not believe I am subject to the Health Insurance Claims Assessment (HICA). What should I do?
  My business activity has changed, and I am no longer subject to the Health Insurance Claims Assessment (HICA). Who do I notify?
  Who do I contact if I have questions about the Health Insurance Claims Assessment (HICA)?
  What health-related services are subject to the Health Insurance Claims Assessment (HICA)?
  Who is a Michigan resident for purposes of the Health Insurance Claims Assessment (HICA) Act?
  Are there health-related claims that the Health Insurance Claims Assessment (HICA) does not apply to?
  The Health Insurance Claims Assessment (HICA) Act provides for a cap on the assessment of $10,000 "per insured individual or covered life annually." In the case of an individual using more than one insurer, is the assessment limited to $10,000 per insurer used by the individual? Or is the limit $10,000 total for all "paid claims" regardless of the number of insurers the individual has used in accumulating the claims?
  Most employees participate to some extent in the cost of their employer-sponsored health insurance. In anticipation of the new Health Insurance Claims Assessment (HICA) being added on to our monthly health insurance billing statements by our carrier, as an employer, is there any rule restricting an employer from passing the cost of the HICA assessment on to its employees?
  Other taxes administered by Treasury typically have a filing threshold, below which the tax does not have to be paid. Is this true of the Health Insurance Claims Assessment (HICA) Act?
  The Health Insurance Claims Assessment (HICA) Act provides for credits to be issued to payers when the assessment brings in more than $400 million in a year. When credits are issued due to the cap being reached, if the entity that deserves the benefit of the credit is no longer serviced by the third party administrator, or has no claims activity, should a refund be requested from the State so that a refund can be sent to the entity?
  Who must pay the Health Insurance Claims Assessment (HICA)? 
  Is there a difference between the Health Insurance Claims Assessment (HICA) and "Intent to Assess" and "Final Assessment" letters?
 
  Annual Return
  How will I know if Treasury has accepted my Health Insurance Claims Assessment (HICA) annual return?
  If I paid Health Insurance Claim Assessment (HICA) during the return year 2012, and my business was closed in 2013, do I qualify for the Proportional Credit if it is available for the return year 2012?
  How do I receive a paper copy of my Health Insurance Claims Assessment (HICA) annual return for my records?
  Is there a way to save a partially completed Health Insurance Claims Assessment (HICA) annual return to come back and finish later?
  How do I calculate interest?
  Can I submit my Health Insurance Claims Assessment (HICA) annual return now, but make my payment at a later date?
  How do I calculate penalty?
  If I make a mistake on my Health Insurance Claims Assessment (HICA) annual return, can I correct it?
  How do I file the Health Insurance Claims Assessment (HICA) annual return?
  Can I send in a paper Health Insurance Claims Assessment (HICA) annual return?
  How do I log in to gain access to e-file the Health Insurance Claims Assessment (HICA) annual return?
  How do I file the Health Insurance Claims Assessment (HICA) annual return if my business is located outside of the United States?
  If I discontinue my business during the year, when do I need to file the Health Insurance Claims Assessment (HICA) annual return?
  When will the Health Insurance Claims Assessment (HICA) annual return e-file system be available?
 
  Payments and Returns
  How do I determine the amount of my quarterly Health Insurance Claims Assessment (HICA) payment?
  How do I register as a Health Insurance Claims Assessment (HICA) payer?
  How do I calculate penalty?
  How do I calculate interest?
  Can I mail my Health Insurance Claims Assessment (HICA) payment?
  What should I do if my Health Insurance Claims Assessment (HICA) quarterly payment is due on a weekend, legal banking holiday or a holiday recognized by Michigan?
  How will I know if Treasury has accepted my Health Insurance Claims Assessment (HICA) payment?
  Is there a way to review my Health Insurance Claims Assessment (HICA) payment history?
  Can I submit a quarterly Health Insurance Claims Assessment (HICA) payment after the due date?
  I believe I have overpaid on my quarterly Health Insurance Claims Assessment (HICA) payment, what should I do?
  Can I make more than one Health Insurance Claims Assessment (HICA) payment per quarter?
  On the annual return for the Health Insurance Claims Assessment (HICA) Act assessment, will we be expected to show gross paid claims and then each type of exclusion as a separate line item? If our record keeping system allows for specific queries that would give us the net amount, will we be permitted to show only the net amount?
 
  Electronic Funds Transfer
  How do I register to make Health Insurance Claims Assessment (HICA) payments by Electronic Funds Transfer (EFT)?
  Can I mail my Health Insurance Claims Assessment (HICA) payment?
  Is there a fee to submit Health Insurance Claims Assessment (HICA) payments using Electronic Funds Transfer (EFT)?
  What is the format for submitting the Health Insurance Claims Assessment (HICA) quarterly payments?
  What is an ACH Transaction?
  What is the difference between an Electronic Funds Transfer (EFT) Debit payment and an EFT Credit payment?
  Do I need to notify my financial institution when making an Electronic Funds Transfer (EFT) Debit payment?
  What is an International ACH Transaction (IAT)?
 
  Entities Subject to HICA
  I received a notification letter from Treasury, but do not believe I am subject to the Health Insurance Claims Assessment (HICA). What should I do?
  My business activity has changed, and I am no longer subject to the Health Insurance Claims Assessment (HICA). Who do I notify?
  Does the Health Insurance Claims Assessment (HICA) apply to employers that self-insure for health care?
  We are a third party administrator. Our clients have zero balance checking accounts and fund only claims to be paid, into their own individual bank accounts. If we pass through the 1% Health Insurance Claims Assessment (HICA) Act assessment to our clients and they do not or cannot pay the pass-through amount, will we as the third party administrator be penalized? Who is responsible if one of our clients cannot or does not pay the 1% assessment? What happens if the client goes bankrupt, and has no funds? How does the 1% assessment get paid?
  We are a third party administrator. We do not actually "pay" claims for our clients, we only process those claims. The funds to pay the claims come directly from our clients' bank accounts. Since we are not "paying" any claims, we have no "paid claims" and therefore, no liability under the Health Insurance Claims Assessment (HICA) Act. Is this correct?
  Who must pay the Health Insurance Claims Assessment (HICA)? 
  Does the Health Insurance Claims Assessment (HICA) Act apply to non-taxable entities such as school districts and municipalities?
 
  Determining Which Entity Must Pay
  My company is self-insured, but we do use a Third-Party Administrator (TPA) for claims-related services. Can we pay the Health Insurance Claims Assessment (HICA) on our "paid claims" ourselves, or should the HICA be paid by our TPA?
  If stop loss or excess insurance is purchased by a health plan sponsor, who is responsible for paying the Health Insurance Claims Assessment (HICA) on an excess claim? Is it the third party administrator, or the stop loss carrier?
  Most employees participate to some extent in the cost of their employer-sponsored health insurance. In anticipation of the new Health Insurance Claims Assessment (HICA) being added on to our monthly health insurance billing statements by our carrier, as an employer, is there any rule restricting an employer from passing the cost of the HICA assessment on to its employees?
  It appears that a group health plan sponsor will have to pay their assessment to the third party administrator and then the third party administrator will remit the assessment to Treasury. How can the health plan sponsor, shortly after the quarterly payment date, get confirmation from Treasury that the monies were received from the third party administrator?
  If stop loss or excess insurance is purchased by a health plan sponsor, who is responsible for paying the Health Insurance Claims Assessment (HICA) on an excess claim? Is it the third party administrator, or the stop loss carrier?
 
  "Paid Claims"
  Are carriers of Medicare supplemental insurance subject to the assessment under the Health Insurance Claims Assessment (HICA) Act? Should claims paid under Medicare supplemental coverage be included when determining the amount of the assessment that must be paid?
  An employer pays a third party administrator to administer its wellness program, which includes a screening, a risk assessment, and an annual physical. Are such wellness expenses covered by the Health Insurance Claims Assessment (HICA)?
  The Health Insurance Claims Assessment (HICA) Act refers to "ambulatory services" as one type of health and medical service that is subject to the assessment. What are "ambulatory services"?
  Are dental services subject to the Health Insurance Claims Assessment (HICA)?
  We are a licensed third party administrator in Michigan. We do not service any self-funded employers located in Michigan, but we do service employers in other states who have employees living in Michigan. Does the Health Insurance Claims Assessment (HICA) Act require the employer plan to be domiciled in Michigan, or does the assessment apply to any resident of Michigan who obtains health care services or prescriptions in Michigan, regardless of where his/her employer is located?
  Who is a Michigan resident for purposes of the Health Insurance Claims Assessment (HICA) Act?
  Is "durable medical equipment" subject to the Health Insurance Claims Assessment (HICA)?
  Are vision-related services subject to the Health Insurance Claims Assessment (HICA)?
  We are a third party administrator that is subject to the Health Insurance Claims Assessment (HICA) Act. Doctors and other providers often use billing services, and we frequently pay claims where the medical service provided is billed through such a billing service. However, there is not necessarily an indication on the claim where the actual service was performed, and the billing service is sometimes in a different state than where the doctor or provider is located. How do we handle these kinds of claims for purposes of the HICA assessment? 
  For services provided by a pharmacist, does the Health Insurance Claims Assessment (HICA) apply to the price of the pharmaceutical products or drugs?
  Are claims for prescription drugs, purchased through a mail-order pharmacy and delivered to a Michigan resident, subject to the Health Insurance Claims Assessment (HICA)?
  "Paid claims" is defined as actual payments, net of recoveries. Does "recoveries" encompass only amounts recouped from the provider, or does it include other amounts received by the payer, such as rebates or payments from third parties?
 
  Exclusions from "Paid Claims"
  What health-related services are subject to the Health Insurance Claims Assessment (HICA)?
  The only service provided by a licensed Third Party Administrator (TPA) in Michigan is health care and dependent care flex benefit administration for a client. The TPA receives the employees' payroll deductions for health and dependent care and makes reimbursements to these employees when they submit the required documentation showing out of pocket payments for co-pays etc. and dependent care costs. Are the payments made by this TPA subject to the assessment?
  Are there health-related claims that the Health Insurance Claims Assessment (HICA) does not apply to?
  Does the Health Insurance Claims Assessment (HICA) Act apply to an indemnity only insurance product? For example, the insured suffers a broken arm and the carrier pays $500 directly to the insured, regardless of treatment expense? 
  How should "domestic claims" between hospitals and their employees be treated for purposes of the Health Insurance Claims Assessment (HICA) Act? Typically, when a hospital employee has treatment at the employer hospital, a claim is submitted for eligibility verification and internal accounting purposes, but no money is paid to the hospital for the services provided.
  Are payments made pursuant to a health reimbursement account excluded from the Health Insurance Claims Assessment (HICA) Act? 
  Our company, located in Michigan, is a self-insured entity for worker's compensation only. Does the Health Insurance Claims Assessment (HICA) Act apply to payments made on worker's compensation claims?
  If a payment from a health reimbursement account is made directly to a provider, would that payment be subject to the Health Insurance Claims Assessment (HICA)? The wording of the statute only specifically excludes payments made to individuals.
  The Health Insurance Claims Assessment (HICA) Act provides for a cap on the assessment of $10,000 "per insured individual or covered life annually." In the case of an individual using more than one insurer, is the assessment limited to $10,000 per insurer used by the individual? Or is the limit $10,000 total for all "paid claims" regardless of the number of insurers the individual has used in accumulating the claims?
 
  Prescription Drugs and Pharmacy Benefit Managers
  For services provided by a pharmacist, does the Health Insurance Claims Assessment (HICA) apply to the price of the pharmaceutical products or drugs?
  Are Pharmacy Benefits Managers responsible for paying the 1% assessment under the Health Insurance Claims Assessment Act (HICAA)?
  We are a Pharmacy Benefits Manager (PBM). We process prescription drug claims for self-insured entities. We pay pharmacies for prescriptions that are filled, and then charge our employer client for that cost plus an administrative fee. How do we determine the amount of the assessment under the Health Insurance Claims Assessment Act (HICAA) that is owed with respect to each claim? Is the assessment determined by the amount the PBM pays to the pharmacy, or the amount that the PBM charges to the employer client?
  Are claims for prescription drugs, purchased through a mail-order pharmacy and delivered to a Michigan resident, subject to the Health Insurance Claims Assessment (HICA)?
  Can rebates received by a Pharmacy Benefit Manager from drug companies be netted as "recoveries" against the PBMs "paid claims" for purposes of the Health Insurance Claims Assessment (HICA)?
 
  Medicaid-Related Services
  Are carriers of Medicare supplemental insurance subject to the assessment under the Health Insurance Claims Assessment (HICA) Act? Should claims paid under Medicare supplemental coverage be included when determining the amount of the assessment that must be paid?
  Are self-determination services paid by a Prepaid Inpatient Health Plan (PIHP) at the direction of a consumer subject to the Health Insurance Claims Assessment (HICA)?
  A Program for All Inclusive Care for the Elderly (PACE) hires its own staff to handle patients, paying those individuals salaries. No personnel are paid on a per-claim basis. Does the PACE have to pay the Health Insurance Claims Assessment (HICA) on the salaries it pays?
  A Program for All Inclusive Care for the Elderly (PACE) contracts with other organizations to perform medical services, and pays those organizations a capitated payment every month. This payment covers all eligible beneficiaries, and is not on a per-claim basis. Who is responsible for paying the Health Insurance Claims Assessment (HICA) ? the PACE, the subcontracted organization, or neither?
  Is a Program for All Inclusive Care for the Elderly (PACE) subject to the Health Insurance Claims Assessment (HICA)? These programs have outside providers perform medical services, and they are billed by and pay directly to these providers.
  Are claims for hospice care subject to the Health Insurance Claims Assessment (HICA)?
  Are claims paid with State general funds by a County Mental Health organization (CMH) for behavioral health services subject to the Health Insurance Claims Assessment (HICA)?
  Are claims processed on behalf of charitable, non-profit programs, such as programs providing free medical service to the uninsured, subject to the Health Insurance Claims Assessment (HICA)? What about claims processed for jailed inmates?
  Does the Health Insurance Claims Assessment (HICA) apply to MIChild and general fund claims paid to an organization?
  The Health Insurance Claims Assessment (HICA) Act provides in Section 2(b)(ii) that "payments that are made to or by an organized group of health and medical service providers in accordance with managed risk arrangements or network access agreements, which payments are unrelated to the provision of services to specific covered individuals" are considered claims-related expenses, and are thus not subject to the HICA Act assessment. Are subsequent payments made by Medicaid Health Plans (MHPs) related to these amounts subject to the assessment?
  We are a health plan that has been contracted by the Michigan Department of Community Health to provide medical services to beneficiaries under the MIChild program. We have outside providers perform these services, and we are billed by and pay directly to these providers. Are we subject to the Health Insurance Claims Assessment (HICA)?
  We are a County Health Department. We provide medical services both through our own in-house staff and through outside providers. On some occasions, we are paid directly by the Medical Services Administration of the Michigan Department of Community Health, but at other times we are paid by Medicaid Health Plans (MHPs). Are we subject to the Health Insurance Claims Assessment (HICA)?
  We are a Prepaid Inpatient Health Plan (PIHP). We hire our own staff to handle all of our patients, and those individuals are paid salaries. We do not pay anyone on a per-claim basis. Does the Health Insurance Claims Assessment (HICA) apply to the salaries that we pay? Does the source of funding (Medicaid, Adult Benefit Waiver, MIChild, state general funds, etc.) affect whether an amount is subject to the assessment?
  Prepaid Inpatient Health Plans (PIHPs) contract with County Mental Health (CMH) agencies to perform services, paying the organization a capitated payment every month. The payment covers all eligible beneficiaries, and is not on a per-claim basis. Who is responsible for paying the Health Insurance Claims Assessment (HICA) ? the PIHP, the subcontracted CMH, or neither? Does the source of funding (Medicaid, Adult Benefit Waiver, MIChild, state general funds, etc.) affect whether an amount is subject to the assessment?
  We are a Medicaid Health Plan (MHP). We contract with outside providers to perform medical services, and we are billed by and pay directly to these providers. Are we liable for the Health Insurance Claims Assessment (HICA)?
  Are SCHIP funds exempt from the Health Insurance Claims Assessment (HICA), like some other sources of federal funding?
  As a nonprofit dental care corporation, we contract to administer dental services to Medicaid beneficiaries through outside providers, and we are billed by and pay directly to these providers. Are we subject to the Health Insurance Claims Assessment (HICA)?
  We are a Medicaid Health Plan (MHP). We contract with other organizations to perform medical services, paying those organizations a capitated payment every month. The payment is for all eligible beneficiaries, and is not on a per-claim basis. Are these payments subject to the Health Insurance Claims Assessment (HICA)
  We are a Prepaid Inpatient Health Plan (PIHP). We have outside providers perform services, and we are billed by and pay directly to these providers. Are we subject to the Health Insurance Claims Assessment (HICA)? Does the source of funding (Medicaid, Adult Benefit Waiver, MIChild, state general funds, etc.) affect whether a payment is subject to the assessment?
  We are a Community Mental Health organization (CMH). CMHs receive capitated payments monthly from Medicaid for each member within our counties. However, we do not submit claims. Are we required to pay the Health Insurance Claims Assessment (HICA) on the Medicaid payments that we receive each month?
  We are a County Health Plan (CHP), a physical health organization that is paid capitation payments directly by the Michigan Department of Community Health to provide health care to beneficiaries of the Adult Benefit Waiver (ABW) program. We contract with a third party administrator (TPA) that pays the providers for medical services. Who must pay the Health Insurance Claims Assessment (HICA) - us, or our TPA?
  We are a dental insurance carrier. We are wondering how to handle the Health Insurance Claims Assessment (HICA) with respect to subrogated Medicaid claims. Do we pay the assessment on subrogated claims?

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