GBS Health Benefits Compliance
WAPAL Compliance Checklist for Employers [Washington State]
In 2020, the Washington State legislature passed HB 2728 that directed the Health Care Authority (HCA) to collect an assessment (or fee) from health plans based on Washington covered lives in order to fund the Washington Partnership Access Line (WAPAL) Fund. This fund supports behavioral health services for families across the state. HCA has chosen KidsVax to function as the third-party administrator to calculate and administer the assessments.
The WAPAL Fund applies both to self-insured (including level-funded) and fully insured health plans that cover at least one individual residing in Washington State. This includes employees, dependents, COBRA participants, and retirees with Washington addresses. Out-of-state employers that cover Washington residents are subject to the assessment.
Health insurers are responsible for filing and paying the assessment on behalf of their fully insured clients.
Self-funded plans are expected to submit quarterly reports on covered lives through the WAPAL Fund website (using the KidsVax system) within 45 days after the end of each quarter. KidsVax will then issue invoices to plans after receiving the covered lives report. Plans should remit their payments to WAPAL Fund as indicated in the invoice.
- Employers with self-funded plans that cover Washington residents should contact their TPA to see if they are willing to complete and file the reports and assessments on the plan sponsor’s behalf.
- If the TPA is unwilling to assist, the employer as the plan sponsor is responsible to complete the reporting.
Self-funded plan sponsors should take the following steps:
Step 1: Confirm Applicability
Determine whether your plan has covered lives in Washington State (employees, dependents, COBRA, retirees).
- If yes, WAPAL applies.
- If no, reporting is not required.
- Note that if you previously had Washington residents but in a given quarter have zero, you must still file a ‘zero’ report to maintain compliance.
Step 2: Review TPA Responsibilities
Check your TPA agreement to see if WAPAL reporting and payment is included in their services. Confirm your understanding in writing with the TPA and keep in your compliance files. If WAPAL reporting is not covered under the TPA services agreement (or if the TPA is unwilling to assist), the employer (plan sponsor) must take over compliance and submit the quarterly reports and pay the assessment.
Step 3: Register With KidsVax
KidsVax is the third-party administrator for the WAPAL Fund. Register your plan at the assessment portal to create an account to report covered lives and make payments.
Step 4: File Quarterly Covered Lives Report
Log into the KidsVax portal and file quarterly covered lives report within 45 days after the end of each quarter. WAPAL has provided a reporting guide to help employers.
Step 5: Pay Quarterly Assessment as Invoiced
KidsVax will issue invoices to plans after receiving the covered lives report. Plans should remit their payments to the WAPAL Fund as indicated in the invoice. The assessment rate per covered life per month is adjusted for each State Fiscal Year (SFY). For example, the SFY 2025 (July 2024 – June 2025) assessment rate is $0.06 per covered life per month.
Step 6: Document and Establish Ongoing Compliance
Keep records of filed covered lives reports and paid invoices. If TPA is filing and paying on behalf of the plan, keep records of the TPAs communications of that fact. Verify ongoing quarterly reports are made within 45 days after the end of each quarter and that invoices are paid.
Resources and Links
- Health Care Authority (HCA) Partnership Access Lines webpage with general info, FAQs, and employer guidance.
- WAPAL Fund webpage.
- KidsVax registration and login page used for quarterly reporting.
September 2025
This document is not intended to be exhaustive, nor should any information be construed as tax or legal advice.
