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Payor Play Mandate Delayed: Employer Responsibility and Information Reporting On July 2, 2013, the Treasury Department announced that enforcement of the employer shared responsibility payments of the Patient Protection and Affordable Care Act (PPACA) will be delayed by one year, until 2015. Compliance with the law’s information reporting provisions will be voluntary for 2014, but strongly encouraged. Formal guidance is expected within the next week. The Administration said they recognized the information reporting required by insurers, self-insured employers and others providing health coverage is complex so they will try to streamline the requirements over the next few months through discussions with stakeholders. Proposed rules on the reporting requirements are expected to be issued this summer. Without the reporting requirements in place, it would be “impractical to determine which employers owe shared responsibility payments,” according to the post on the Treasury Department’s website. What This Means There will be no penalties in 2014 on businesses that don’t meet the requirements of the “employer mandate.” What’s not changing as a result of these delays:
For more details, here is the link to the Treasury blog post, Continuing to Implement the ACA in a Careful, Thoughtful Manner If you have questions about how the delay of the employer mandate impacts your company, call DDI. We are pleased that businesses will have more time to carefully plan for the changes required due to the employer mandate Source: www.cigna.com
a Refresher on the Employer Mandate Large employers with 50 or more full-time or full-time equivalent employees must offer full-time employees and their dependents (i.e., children up to age 26) coverage that is affordable and provides minimum value beginning in 2014 or face penalties – known as employer shared responsibility payments – if any full-time employee purchases coverage on an Exchange/Marketplace and receives a federal premium subsidy. The Treasury announcement delays penalties for non-compliance until 2015. Employers are still encouraged to maintain or expand health coverage in 2014. Reform Checklist – What Employers Need to Know In most cases your health plan will automatically be adjusted to comply with ACA provision requirements applicable to small group plans by your health insurance provider. The following items become effective Jan. 1, 2014 Plan exclusions are removed for those of any age with a pre-existing condition. This is an update to the provision from 2010 that did not allow exclusions for children under the age of 19 with a pre-existing condition. Plans will provide Essential Health Benefits (EHB). Beginning in 2014, fully insured small group employers are required to cover all Essential Health Benefits specified in the state EHB benchmark plan in their situs state. All annual and lifetime dollar limits will be removed from EHB. To fund some of the changes mandated by the health reform law, several new taxes and fees will impact premiums and rates. Fully insured health plans will see the following health reform fees prorated into their premiums over 12 months. • Patient-Centered Outcomes Research Institute (PCORI) Fee for plan years that ended on or after Oct. 1, 2012, the ACA imposed a temporary fee on health insurance issuers and self-funded plans called the PCORI Fee. The fee is $1 per member per year for the first year, increases to $2 per member per year for the second year and is indexed to medical inflation in subsequent years. The fee began in 2012 and ends in 2019. • The Insurer Fee will be collected from health insurance issuers based on certain net written health insurance premiums for fully insured groups. The annual fee is permanent and expected to total $8 billion in 2014 for all insurers, increasing each year to $14.3 billion in 2018 and increasing by the rate of premium growth thereafter. Based on industry analysis, the impact on premium is about 2.5 percent. • The Transitional Reinsurance Fee will be imposed for the years 2014 to 2016 on health insurance issuers and self-funded group health plans, and the funds will be distributed to insurers in the non-grandfathered individual market that disproportionately attract individuals at risk for high medical costs. The intent is to spread the financial risk across all health insurers to provide greater financial stability. The fee will be assessed on a per capita basis. The health reform law specifies the total amounts of the Reinsurance Fee that must be collected for the reinsurance program: $12 billion in 2014, $8 billion in 2015 and $5 billion in 2016, totaling $25 billion. States are permitted to increase these fees at their discretion, but no state will be increasing its fee for the 2014 benefit year. Based on industry estimates, the average projected cost is about $5 per member per month in 2014, which then decreases each year for the subsequent two years. • A Risk Adjustment Fee of about $1 per member per year is assessed on issuers of risk-adjusted plans in the non-grandfathered individual and small group markets, whether in or out of Exchanges. The permanent fee helps fund the administrative costs of running the Risk Adjustment program. The program is intended to protect health insurance issuers of risk-adjusted plans against adverse selection by redistributing premiums from plans with low-risk populations to plans with high-risk populations. The Risk Adjustment Fee begins in 2014. Adjusted Community Rating (ACR) Health insurance in the individual and small group markets will only be able to vary premiums by family size, geography, tobacco use and age. Other rating factors currently used, such as gender, industry, group size, health status and medical history, will be prohibited. The impact of age factors will be limited to a range of 3 to 1. Tobacco users may also have their premium varied by up to 50 percent higher than non-tobacco users. As a result of these changes, a significant number of employers will realize more substantial increases than under currentrequirements. Annual limitation on plan deductibles is $2,000 single/$4,000 family. This applies to non-grandfathered small groups with the exception of 50-plus as they are not considered small group. There is an exception for leaner plans if you cannot “reasonably” meet the approved actuarial values with a $2,000 deductible. Cost-sharing towards services will accumulate to your plan’s out-of-pocket maximum, including flat-dollar copayments for services that are defined as EHB beginning in 2014. Out-of-pocket maximums for all non-grandfathered plans will be capped at the same level at which health savings account (HSA) plans are capped. In 2013, these levels are $6,350 single/$12,700 family. Small Business Tax Credit– Employers with fewer than 25 employees should check to see if they qualify for the Small Business Tax Credit. For tax years beginning in 2014, the credit will be available only to small businesses that purchase health coverage through an Exchange, also called a Health Insurance Marketplace. You should seek advice from an accountant and attorney to determine how the credit may affect your specific situation. Limit employee contributions to health flexible spending accounts (FSA). Employee salary reduction contributions to health FSAs will be limited to $2,500 per plan year, with indexed increases allowed in future years to adjust for inflation. Provide written notice about Exchanges, also called Health Insurance Marketplaces Applicable employers must provide written notice to current employees by Oct. 1, 2013, and new employees within 14 days of their start date to inform them of their coverage options Source: www.uhc.com For more information on creating a customized benefits package for your employees,
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Medicare Disclaimer: We do not offer every plan available in your area. Currently, we represent 7 organizations which offer 35 products in Oregon and Washington. Please contact medicare.gov or 1-800-MEDICARE, or your local State Health Insurance Program to get information on all your options. Please note that we are required to record all phone conversations with clients who want to discuss Medicare Advantage and/or Part D prescription drug plans. We are not connected with or endorsed by the United States government or the federal Medicare program.
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Medicare Disclaimer: We do not offer every plan available in your area. Currently, we represent 7 organizations which offer 35 products in Oregon and Washington. Please contact medicare.gov or 1-800-MEDICARE, or your local State Health Insurance Program to get information on all your options. Please note that we are required to record all phone conversations with clients who want to discuss Medicare Advantage and/or Part D prescription drug plans. We are not connected with or endorsed by the United States government or the federal Medicare program.
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