Health care reform imposed on all health plans a Transitional Reinsurance Fee (TRF) for three years— 2014 through 2016. For 2015 and 2016, there is an exemption from the TRF program for self-insured plans that self-administer claims.

This exemption has been widely touted as a multiemployer or union-based plan exemption. However, the trust does not qualify for the exemption because the exemption does not apply to any plans that hire third-party administrators for enrollment or claims processing (other than for pharmacy benefits or excepted benefits).