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Self-Insured

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What is a Self-Insured Health Plan?

Last Updated: August 22, 2017

Self-insured companies pay for employee health insurance claims directly, either out of pocket or through special funds earmarked for this purpose. This means that the company assumes a financial risk for each employee and does not have a traditional “fully-insured” plan through a commercial insurance company. Some self-insured plans are...

Why Do Self-Insured Claims Need to be Included in the CO APCD?

Last Updated: August 22, 2017

Currently the CO APCD contains information from commercial health plans (with the exception of self-insured claims) as well as Medicaid and Medicare Advantage. Self-insured claims represent approximately 30 percent of insured lives in CO and pose a significant gap in the market when it comes to analyzing data in the...

I’m a self-insured, employer-funded health plan regulated by ERISA (“ERISA plan”). Am I required to submit health claims data to the CO APCD?

Last Updated: August 22, 2017

Although Colorado can no longer require ERISA plans to submit claims data to the CO APCD, CIVHC will continue to accept claims data that is voluntarily submitted by or on behalf of ERISA plans going forward. 

As an ERISA plan, what happens to the data my ASO/TPA submitted on my behalf prior to the Supreme Court’s March 1, 2016 decision? Will the data be used in public and non-public data releases moving forward?

Last Updated: August 22, 2017

Claims data submitted by or on behalf of ERISA plans prior to the Supreme Court’s decision in Gobeille will remain a valuable part of the CO APCD and will be treated the same as data submitted from any other category of payer. Data contained in the CO APCD is used...

If I’m another category of payer, not an ERISA plan, can I stop submitting data to the CO APCD?

Last Updated: August 22, 2017

No. The Supreme Court’s decision only applies to a narrow subsection of payers – specifically, to ERISA plans.  The decision does not affect the legal obligation under the Colorado statute and implementing regulations for non-ERISA self-funded employer sponsored health plans that have 100 or more covered lives or any other...

I’m an ERISA plan. I have not yet submitted any data to the CO APCD and have not submitted an opt-out form. Do I still need to submit an opt-out form and will there be any penalties for my failure to timely submit an opt-out form?

Last Updated: August 22, 2017

No.  ERISA plans no longer need to submit opt-out forms, and there will there be no penalties for ERISA plans who failed to timely submit opt-out forms by the original December 28, 2015 deadline.

Is there a cost to submit?

Last Updated: August 22, 2017

There is no cost from CIVHC to include your claims in the CO APCD. Many ASOs and TPAs are not charging clients for this service. We suggest you check with your ASO or TPA directly to confirm.