If anyone has ever had to sign a contract of any kind, then they know how often it requires a signature – often on multiple pages.
Since 2005, United Benefit Advisors® (UBA) has surveyed thousands of employers across the nation regarding their health plan offerings, their ongoing plan decisions in the face of significant legislative and marketplace changes, and the impact of these changes on their employees and businesses.
Since 2005, United Benefit Advisors® (UBA) has surveyed thousands of employers across the nation regarding their health plan offerings, their ongoing plan decisions in the face of significant legislative and marketplace changes, and the impact of these changes on their employees and businesses.
If anyone has ever had to sign a contract of any kind, then they know how often it requires a signature – often on multiple pages.
Question: What are the Employee Retirement Income Security Act (ERISA) rules about nondiscrimination in benefits plan designs to assist with creating benefit class carve-outs? Answer: Under the Health Insurance Portability and Accountability Act (HIPAA, which is governed by ERISA) and I.R.C. ยง 125 plan rules, employers are allowed to offer different contribution levels or benefit … Continued
Beginning in 2015, large employers must offer affordable, minimum value coverage to their full-time employees or potentially pay a penalty. Some companies have been marketing a plan that they state satisfies the minimum value requirement (an actuarial value of 60%), based upon a calculator provided by the Department of Health and Human Services (HHS), even though the plan does not cover inpatient hospital charges. In Notice 2014-69, HHS and the IRS state that plans that do not provide substantial coverage for physician and inpatient hospital services will not be considered minimum value plans, and that the result obtained through the HHS calculator should not be considered valid since that calculator was built on the assumption that a traditional plan design would be used. The agencies do recognize that some employers have already implemented these plans based on the calculator results, and the Notice states that a limited exception will be available to those employers. To be able to use the exception:
Employees who are offered coverage under one of these “non-hospital/non-physician services plans” will be eligible to receive a premium tax credit, as long as the other criteria to receive a tax credit are met. However, employers that can meet the limited exception will be considered to have offered minimum value coverage for the 2015 plan year and will not owe a penalty for the 2015 plan year even if the employee receives a premium tax credit. Beginning in 2016 non-hospital/non-physician services plans will not be considered minimum value for any employers, so employers that qualify for the limited exception will be subject to penalties on employees who receive a premium tax credit unless they offer more complete coverage.
This notice only applies to plans that claim to offer minimum value coverage even though they do not provide significant coverage for inpatient hospital and physician services. Although some have reported that “skinny” and “MEC” plans are no longer allowed, that is not correct. Plans that limit coverage to preventive care (often referred to as “skinny” or “MEC” plans) are permitted and appear to meet the criteria to be considered “minimum essential coverage.” Employers may continue to offer a non-hospital/non-physician services plan, and that plan likely will meet the requirement to offer minimum essential coverage, but it will not meet a requirement to offer minimum value coverage.
To get the latest information on other plan designs being disallowed—such as employer reimbursement of premiums for individual coverage, incentivizing employees in poor health to enroll in the marketplace, and more—download UBA’s PPACA Advisor, “Agencies Disallow Several Plan Designs; Other Federal Developments”.
Tuesday, December 9, 2014
2:00 p.m. ET / 11:00 a.m. PT
Tuesday, December 9, 2014
2:00 p.m. ET / 11:00 a.m. PT
Question: Are we required to have employees complete wellness reward screenings which impact health care premiums, prior to the new plan year beginning? Answer: While some employers do take this approach, it may be possible for employers to apply premium reductions for those who complete the required screenings mid-year. The challenge relates to compliance with … Continued
The Centers for Medicare and Medicaid Services (CMS) extended the deadline for group health plans to provide their 2014 transitional reinsurance fee (TRF) submission. Filing is now due by 11:59 p.m. on December 5, 2014. The January 15, 2015, and Novemb…