VEBA Administrators take note:

Section 9010 of the Patient Protection and Affordable Care Act (ACA) imposes a fee on each covered entity engaged in the business of providing health insurance for United States health risks.  The first fees are due September 30, 2014.  Importantly, VEBAs along with (self insured employers and certain non-profit corporations), are EXCLUDED from this fee. 

Accordingly, such fees should not be accounted for nor passed along to VEBA plan participants.