archive for the ‘Health Care Reform’ category
Posted by Todd McDonald on June 16, 2010
There is considerable uncertainty about what choices employers will make over the next few years as the market prepares for the establishment of the competitive Exchanges and other market reforms such as new consumer protections, middle-class tax credits and other steps to expand affordability and choice for millions more Americans. Below is a fact sheet that provides additional information about grandfathered plans.
Protecting Patients’ Rights in All Plans
All health plans – whether or not they are grandfathered plans – must provide certain benefits to their customers for plan years starting on or after September 23, 2010 including:
- No lifetime limits on coverage for all plans;
- No rescissions of coverage when people get sick and have previously made an unintentional mistake on their application; Extension of parents’ coverage to young adults under 26 years old; and the
For the vast majority of Americans who get their health insurance through employers, additional benefits will be offered, irrespective of whether their plan is grandfathered, including:
- No coverage exclusions for children with pre-existing conditions; and
- No “restricted” annual limits (e.g., annual dollar-amount limits on coverage below standards to be set in future regulations).
Additional Consumer Protections Apply to Non-Grandfathered Plans
Grandfathered health plans will be able to make routine changes to their policies and maintain their status. These routine changes include cost adjustments to keep pace with medical inflation, adding new benefits, making modest adjustments to existing benefits, voluntarily adopting new consumer protections under the new law, or making changes to comply with State or other Federal laws. Premium changes are not taken into account when determining whether or not a plan is grandfathered.
Plans will lose their grandfathered status if they choose to make significant changes that reduce benefits or increase costs to consumers. If a plan loses its grandfathered status, then consumers in these plans will gain additional new benefits including:
- Coverage of recommended prevention services with no cost sharing; and
- Patient protections such as guaranteed access to OB-GYNs and pediatricians.
Under the Affordable Care Act, these requirements are applicable to all new plans, and existing plans that choose to make the following changes that would cause them to lose their grandfathered status.
Compared to their polices in effect on March 23, 2010, grandfathered plans:
- Cannot Significantly Cut or Reduce Benefits. For example, if a plan decides to no longer cover care for people with diabetes, cystic fibrosis or HIV/AIDS.
- Cannot Raise Co-Insurance Charges. Typically, co-insurance requires a patient to pay a fixed percentage of a charge (for example, 20% of a hospital bill). Grandfathered plans cannot increase this percentage.
- Cannot Significantly Raise Co-Payment Charges. Frequently, plans require patients to pay a fixed-dollar amount for doctor’s office visits and other services. Compared with the copayments in effect on March 23, 2010, grandfathered plans will be able to increase those co-pays by no more than the greater of $5 (adjusted annually for medical inflation) or a percentage equal to medical inflation plus 15 percentage points. For example, if a plan raises its copayment from $30 to $50 over the next 2 years, it will lose its grandfathered status.
- Cannot Significantly Raise Deductibles. Many plans require patients to pay the first bills they receive each year (for example, the first $500, $1,000, or $1,500 a year). Compared with the deductible required as of March 23, 2010, grandfathered plans can only increase these deductibles by a percentage equal to medical inflation plus 15 percentage points. In recent years, medical costs have risen an average of 4-to-5% so this formula would allow deductibles to go up, for example, by 19-20% between 2010 and 2011, or by 23-25% between 2010 and 2012. For a family with a $1,000 annual deductible, this would mean if they had a hike of $190 or $200 from 2010 to 2011, their plan could then increase the deductible again by another $50 the following year.
- Cannot Significantly Lower Employer Contributions. Many employers pay a portion of their employees’ premium for insurance and this is usually deducted from their paychecks. Grandfathered plans cannot decrease the percent of premiums the employer pays by more than 5 percentage points (for example, decrease their own share and increase the workers’ share of premium from 15% to 25%).
- Cannot Add or Tighten an Annual Limit on What the Insurer Pays. Some insurers cap the amount that they will pay for covered services each year. If they want to retain their status as grandfathered plans, plans cannot tighten any annual dollar limit in place as of March 23, 2010. Moreover, plans that do not have an annual dollar limit cannot add a new one unless they are replacing a lifetime dollar limit with an annual dollar limit that is at least as high as the lifetime limit (which is more protective of high-cost enrollees).
- Cannot Change Insurance Companies. If an employer decides to buy insurance for its workers from a different insurance company, this new insurer will not be considered a grandfathered plan. This does not apply when employers that provide their own insurance to their workers switch plan administrators or to collective bargaining agreements.
Protecting Against Abuse of Grandfathered Health Plan Status
To prevent health plans from using the grandfather rule to avoid providing important consumer protections, the regulation provides for:
- Promoting transparency by requiring a plan to disclose to consumers every time it distributes materials whether the plan believes that it is a grandfathered plan and therefore is not subject to some of the additional consumer protections of the Affordable Care Act. This allows consumers to understand the benefits of staying in a grandfathered plan or switching to a new plan. The plan must also provide contact information for enrollees to have their questions and complaints addressed;
- Revoking a plan’s grandfathered status if it forces consumers to switch to another grandfathered plan that, compared to the current plan, has less benefits or higher cost sharing as a means of avoiding new consumer protections; or
- Revoking a plan’s grandfathered status if it is bought by or merges with another plan simply to avoid complying with the law.
If you have any specific questions about implementation, please contact us as soon as possible to discuss these significant health care reform changes.
Posted by Todd McDonald on May 19, 2010
What Health Care Reform Means For Your Business
Wednesday, June 02, 2010 11:00 AM – 12:30 PM (Eastern Time)
Back by Popular Demand!
This webinar is the second in our series on Health Care Reform. This session discusses in greater detail the immediate concerns affecting your plans in 2010 and 2011. Takeaways include strategies on dealing with rate hikes, dependent status, small business tax credits, and keeping your grandfathered status.
Other changes include shortened presentations to accommodate for a more rigorous Q&A. Participants are encouraged to submit questions to pate.steele@grahall.com prior to the event.
This webinar will recap all of the key points of the new health care reform bill, the Patient Protection and Affordable Care Act (PPACA), and will provide you with an understanding of how these new regulations will impact you, your employees, and your business, including the impact on costs, coverage, plan design, and more.
The webinar is being provided as a complementary service to clients of Grahall Consulting Partners, Aisling Partners, and UHY Advisors. However, non-member registrations will also be accepted.
For an agenda, list of speakers, and key takeaways, click here.
We look forward to your participation.
Todd C. McDonald
Posted by Todd McDonald on May 12, 2010
On May 10, 2010, the Departments of Labor, Health and Human Services and Treasury issued regulations implementing the Affordable Care Act by expanding coverage for adult children up to age 26. The benefits become effective for plan years beginning on or after Sept. 23, 2010. For calendar year plans, that will mean the provisions will become effective beginning Jan. 1, 2011.
Key elements include:
- Coverage Extended to More Children
- All Eligible Young Adults Will Have An Enrollment Opportunity
- Same Benefits/Same Price
But, the rules allow an exception for employer-sponsored health plans that were in existence on March 23, 2010 when President Obama signed the healthcare bill. In general, such health plans can exclude adult children of workers until 2014 if the children have access to insurance through another employer-sponsored health plan.
In addition, health care reform critics claim that that some families could pay a price if they seize the chance offered by the new healthcare law to keep children up to age 26 on their insurance policies. That is because until 2014, when health plans will be prohibited from charging higher premiums based on preexisting conditions, insurers in the individual market can take into account the young adult’s medical condition when setting the family’s premium. And, under certain circumstances, families could be required to pay extra to carry young adults on their policies.
Above all, please remember to ask for guidance and to double check the new regulations before modifying or adjusting the features of your health and wellness programs. Proceeding with caution may prevent you from losing your grandfathered status unintentionally.
For More Information
For more information about the impact of health care reform on your business, download the material from our recent webinar which covered all of the key points of the new health care reform bill, the Patient Protection and Affordable Care Act (PPACA).
Pay particular attention to the 2010 and 2011 timetable of events listed in the UHY Advisors Health Care Reform Overview to make sure you are in compliance with these new regulations, some of which are now in effect.
Please contact us for information or assistance.
Posted by Todd McDonald on April 19, 2010
What Health Care Reform Means For Your Business Tuesday, May 04, 2010 11:00 AM – 12:30 PM (Eastern Time)
Click Here To Register
This webinar will cover all of the key points of the new health care reform bill, the Patient Protection and Affordable Care Act (PPACA), and will provide you with an understanding of how these new regulations will impact you, your employees, and your business, including the impact on costs, coverage, plan design, and more.
The PPACA will affect all employers, both large and small. If you are a Business Owner, CFO, Human Resources Officer, or a Benefits Manager, this 90 minute seminar is not to be missed. Our experts will summarize the key points of health care reform, provide the answers to commonly asked questions, and then will then discuss alternative action plans to help you develop your response to the PPACA. In addition, you can take advantage of two opportunities to ask questions: You can send your questions to the presenters prior to the webinar, or pose them during the last half of the webinar will feature a live question-and-answer session.
The webinar is being provided as a complementary service to clients of Grahall Consulting Partners, Aisling Partners, and UHY Advisors. However, non-member registrations will also be accepted.
For an agenda, list of speakers, and key takeaways, click here.
We look forward to your participation.
Todd C. McDonald
Posted by Todd McDonald on April 12, 2010
Dear Aisling Partners Client:
We know many of you have questions about what the newly passed health care reform legislation, H.R. 3590, contains and how it will impact you. We are working hard to provide you with the information and tools you need to better understand the changes and communicate what you need to know moving forward.
As such, I wanted to offer you an additional resource that may prove helpful in keeping track of the many changes currently taking place in the marketplace.
National Association of Underwriters Client Resource Center
The National Association of Health Underwriters (NAHU) has assembled a Client Resource Center to help Aisling and our clients stay abreast of regulatory, compliance, and other health care issues. The primary link to the Resource Center is http://www.nahu.org/legislative/clients/index.cfm.
Current releases include:
What’s Next?
In addition, Aisling Partners in connection with UHY Advisors and Grahall Consulting Partners, LLC will be hosting a free webinar regarding Health Care Reform during the first week of May 2010. The webinar will be offered exclusively to our clients and will outline what you need to know about the newly passed legislation and the changes being implemented over the next few years.
You will receive a client invitation early next week. Please mark your calendar for this important event.
In the meantime, feel free to call us for information or to request assistance in reviewing any health care or expected compliance or renewal issues in 2010.
Thank you for your continued vote of confidence in our firm!
Todd C. McDonald
Posted by Todd McDonald on April 5, 2010
The Massachusetts Division of Insurance has disapproved most of the 2nd quarter health insurance rates filed by the Massachusetts health insurance carriers.
Click here to view the press release from the Division of Insurance.
We are fielding calls from many of you regarding the impact to your rates for April, May and June renewals. We are also just beginning to hear from the carriers about how they intend to handle this news.
We anticipate that once the market rates are established, some of our clients may wish to change coverage from their renewal decisions. In the coming days and weeks, we will work closely with each one of you to re-evaluate your decisions and help you to implement the carrier and products that produce the best value for you and your employees.
As each carrier may have different policies and procedures, we will sort out the details to address any potential off-anniversary changes.
We will provide you with any relevant information as soon as it becomes available. In the meantime, please feel free to call me to discuss your concerns and I will do my best to answer your particular questions.
If you have any specific questions about implementation, please contact us as soon as possible to discuss these significant health care reform changes.
Posted by Todd McDonald on March 30, 2010
We know many of you have questions about what the newly passed health care reform legislation, H.R. 3590, contains and how it will impact you. Aisling is working hard to provide you with the information and tools you need to better understand the changes and communicate what you need to know moving forward.
The amount of information about the reform bills being released right now is staggering, and Aisling feels that it is very important to make sure we analyze these measures thoroughly to help you provide the most accurate information. We ask that you keep in mind that the passage of this legislation is just the beginning point, and the implementation and regulatory processes surrounding these measures will take years.
The National Association of Health Underwriters (NAHU) has assembled two new charts to explain the timeline for implementation of the law. The first is a very detailed chart that explains how all of the new health insurance reforms in both the Senate bill and the reconciliation bill will impact private health insurance organized by effective date. The second chart is a simplified timeline that explains how both pieces of health care reform legislation will impact your programs.
In addition, NAHU CEO Janet Trautwein and senior government affairs staff will be hosting a free webinar, Health Reform: The Changes You Need to Know, on Monday, March 29, at 1:00 p.m. EDT. The webinar will outline what you need to know about the newly passed legislation and the changes being implemented over the next few years. To register, click here. Registration is limited to the first 1,000 participants, but the call will be recorded and repeated if necessary. Aisling encourages our clients to participate in the call.
If you have any specific questions about implementation, please contact us as soon as possible to discuss these significant health care reform changes
Posted by Todd McDonald on March 3, 2010
Dear Aisling Partners Client:
On behalf of Aisling Partners, I would like to update you on a couple health care initiatives currently taking place in Massachusetts that may prove to be positive for small businesses:
The Affordable Health Care Plan
First, from a legislative standpoint, Harriett Stanley and Senator Richard Moore have filed a proposal known as the Affordable Health Care Plan. This bill would require health plans as well as providers to control their costs which could reduce premiums for small businesses on comparable products by as much as 22%. Legislative hearings are scheduled for the month of March to bring all stakeholders (insurance carriers, providers, employers, and others) together in an effort to provide much needed relief to small businesses in Massachusetts. The Affordable Health Care Plan has the potential to provide immediate and significant savings to you and your employees.
Business Express
The second initiative now underway is Business Express, a new product being offered through the Massachusetts Health Connector Plan. The state has taken the liberty to send out letters directly to all employers with fifty or fewer employees announcing the new program and highlighting some possible savings. Although there is much speculation about this new platform and its ability to meet financial and contractual needs of small businesses, Aisling Partners will explore this new product / distribution channel on behalf of all of our clients. We are an independent firm committed to providing optimal solutions and we will not overlook any opportunity, including Business Express, to provide the best advice, guidance, and counsel to you and your employees.
What’s Next?
As the letter states, In times like these, you owe it to yourself to compare and select the health plan that is right for you and your employees. This statement could not be more true and we would ask for your continued support in allowing Aisling Partners to explore Business Express, and all other available options, on your behalf in 2010 and beyond.
Feel free to call us for information or to request assistance in looking into these new programs.
Thank you for your continued vote of confidence in our firm!
Todd C. McDonald
Posted by Todd McDonald on January 15, 2010
The Massachusetts Health Care Reform Act, Chapter 58 of the Acts of 2006 as amended, changed the laws to require a broadening of dependent coverage offered by health insurance carriers.
The amendments require that on or after January 1, 2008, carriers with insured health benefit plans that provides for dependent coverage make coverage available for persons “under 26 years of age or for 2 years after the end of the calendar year in which such persons last qualified as dependents, whichever occurs first”.
In some cases the fair market value of coverage provided to dependents who do not meet the IRS definition of a qualified dependent is considered ordinary or “imputed” income and, therefore, subject to federal income taxes as well as FICA tax
A link to the sample certification form outlining both the dependent child eligibility and imputed income requirements in greater details is provided below for your review and consideration. This document can be customized to meet the needs of your company.
Employers should make sure they are in compliance. Please contact us for information or assistance.
Download the certification
Posted by Todd McDonald on November 24, 2009
Under Massachusetts health care reform, employers with 11 or more full-time equivalent employees are required to make a ‘fair and reasonable’ premium contribution toward the cost of their employees’ health insurance or be subject to pay a ‘fair share’ assessment to the state.
The Mass. Division of Health Care Finance and Policy (DHCFP) has announced the adoption of revisions to the Fair Share Contribution (FSC) regulation (114.5 CMR 16.00) effective October 1, 2009. The approved amendments include technical changes to clarify the compliance standards of the FSC requirement. Although the adopted changes to the regulation are relatively minor, three notable revisions to the FSC compliance standards have been adopted:
- Removal of the Majority of Time Rule. The prior version of the regulation stated that, in calculating the percentage of full-time employees enrolled, employees who worked both part-time and full-time during a quarter should be classified based on which capacity the employee worked in for the majority of his or her time. The revised regulation deletes this provision. The regulation now directs employers to identify and record the number of full-time employees enrolled, and the number on the employer’s payroll, on the last day of the quarter.A conservative approach would be to include employees as FT for FSC purposes if they worked 35+ hours during the week inclusive of the end of quarter snapshot date. This approach will increase the number of FT employees included in the denominator of the FSC ratio without a corresponding increase in the number of enrolled FT employees in the numerator; thereby diluting/decreasing the take-up rate. This may not be a problem for large employers with stable employment and high enrollment rates. However, such an approach could be problematic for smaller employers and those without stable employment and/or low enrollment rates.Less conservative approaches may include (a) treating employees as FT for FSC purposes only if the number of weeks they worked 35+ hours in the quarter made them eligible for the employer’s FT health benefit as of the end of quarter snapshot date or (b) averaging the number of hours worked for the quarter.
- Group Health Plan Documentation Requirement. This requires a contributing employer to maintain documentation about its group health plan, including a written plan description for each plan and copies of an employee handbook or other written communication to employees about the plan(s) offered. These documents should contain information on benefits, eligibility (including the minimum number of hours that the employers requires for an employee to be eligible for full-time benefits) and premium contributions. The written plan description should have evidence that the plan was in place during the quarter under review.According to the new requirements, “a contributing employer must maintain documentation about its group health plan and premium contributions including, but not limited to, the following:
- a written plan description for each plan, including a description of benefits, eligibility requirements, and the amount of employer contribution
- evidence that the plan was in place during the quarter for which eligibility is determined; and
- copies of the employee handbook or other written communications to employees about the plan or plans, including plan benefits, eligibility requirements and the employer contributions.”
- Premium Reimbursement Arrangements. These arrangements are now recognized as Group Health Plans under the regulation, provided there is written plan documentation that designates specific insurance plan(s) for use by employees. A PRA may qualify as a group health plan for FSC testing purposes only if the employer:
- designates in writing a specific insurance plan or plans for employee enrollments,
- communicates such designation, in writing, to its employees; and
- otherwise meets the written group health plan documentation criteria in the regulation.
PRAs may help some smaller employers who need only pass one FSC test to pass the Premium Contribution Standard. PRAs will not be a factor for larger employers that must pass both FSC tests (25+% enrollment rate and 33+% contribution rate).
Employers should make sure they are in compliance with these new regulations which are now in effect. Please contact us for information or assistance.
Click here to download the regulations.
