Description: This article will consider several issues arising from ACO budgeting and pricing of stoploss coverage, including: 1) attribution of members; 2) claim carve outs; 3) ambiguous stoploss terms; 4) providers gaming the system and 5) credibility of data.

Description: The PPACA imposed a market share-based health insurance provider fee, known as the "Section 9010 Fee", "Health Insurer Fee", or simply the "HIF", on each “covered entity” with net premiums written in excess of $25 million that is engaged in the business of providing health insurance coverage for U.S. health risks. This article provides background information to help unpack the language behind the Section 9010 Fee and highlights a few areas of special interest including merger and acquisition-related issues, application of the Section 9010 fee to expatriate plans, and considerations regarding fee administration.