Boca Benefits Consulting Group Inc.

 

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Increasing Perceived Incremental “Value Added” of the CPA Firm via Unique Innovation

by

Robert W. Murphy
REBC, ChFC, CLU, RHU, MBA
President/CEO, Boca Benefits Consulting Group, Inc.
Consulting Principal, 1st Murchadhian Strategic Consultancy
727-510-7138 | P.O. Box 4309, Clearwater, FL 33758 | rw_murphy@bocabenefits.com
© December 2010, Boca Benefits Consulting Group, Inc., All Rights Reserved

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Do you attempt to make yourself an integral part of your client/prospect’s management team beyond bookkeeping, payroll, forms preparation and IRS filings? If so, do you clearly differentiate yourself from your CPA peers in the eyes of your clients/prospects CFOs and other top management persons with input into the decisions pertaining to which CPA firm is retained?  The display of uniquely innovative thinking and assistance with persistent management challenges is a key way to do so.

The below summary of marketing tips for CPAs is designed to provide firms with an outline of services of incremental value that your peer CPA firms may not be providing. They are written from the perspective of an employee benefits insurance broker. However, they have been structured to address much broader management issues that the small to mid-size client/prospect might find itself facing in 2010 and onward. Throughout these hints are described various ways in which an HRA (Health Reimbursement Account) can be used to address broader management challenges. The HRA concept is not to be confused with the rest of the benefits alphabet soup of acronyms. It is not an FSA. It is also not an HSA. It is fundamentally different in many ways. Your client/prospect managers responsible for benefits might tell you they know all about HRAs. It is very unlikely, especially given the fact that IRS regs have been evolving right up to 2009 when major changes were made effective. The discussion of uses of an HRA gives you the opportunity to walk benefits managers, CFOs and other senior management persons through solutions that might not have been recognized as such heretofore. Boca Benefits Consulting Group (“BBCG”) can assist you and/or your client/prospect with putting in place the required pieces of those solutions.

These hints have no specific priority order. Some will apply to your clients/prospects and some will not.

∆ Tip 1 of 12:  Show clients/prospects how they can begin, or continue, to offer health insurance assistance to employees without establishing a qualified group health plan.

• Healthcare reform has many smaller employers reconsidering their healthcare approach
•  Recession, premium cost increases, and additional regulatory burden are all catalysts and justifications for scaling down prior employee medical care expenses for smaller employers
• Healthcare reform will eliminate medical underwriting on individual policies once totally implemented in 2014, making all employees insurable
• Current “HIPAA policy” requirements already make every employee individually insurable… at a cost
• Qualified group healthplans have less advantage (i.e., the “guaranteed issue” element whereby all applicants are accepted) than in the past
• IRS regs implementation in 2009 allow individual policy premiums to be paid from HRA contributions made by an employer (n.b., outside or in lieu of a qualified group plan)
• IRS allowable health care expenditures on other products give employees additional options

 ∆ Tip 2 of 12: Show clients/prospects how they can offer health coverage to their employees and save money at the same time. Oriented towards client/prospects which are either not currently providing any employee medical assistance or which are not optimizing available tax advantaged options.

• HRA/Section 125 plan combination allows for both employer contribution to the HRA and “salary reduction” on the part of the employee
• HRA contribution is a tax deductible normal business expense to the employer and is passed tax free to the employee (i.e., treated similar to group insurance premium contributions paid by an employer)
• Total of employees reduced salaries are removed from payroll and all associated payroll taxes and payroll driven charges accrue to the employer as savings
• If properly structured, employee can purchase individual policies completely with pre-tax money saving them 20-30% depending on individual marginal tax bracket

 ∆ Tip 3 of 12: Show your clients/prospects how they can offer some form of health coverage to employees at zero net cost to client/prospect.

• The HRA/Section 125 approach can be used without any initial employer contribution into the HRA
• Payroll tax savings on Section 125 side can ultimately be contributed to the HRA (n.b., a net savings number after administration costs, etc.)
• Employees can choose how they want to use the HRA contribution, subject to limits written into the HRA plan by client/prospect
• Even small HRA contributions can be advantageous to employees (e.g., can be used to pay part of spouse’s healthplan premium elsewhere; inexpensive voluntary benefits allowed by the IRS can be purchased; etc.)

∆ Tip 4 of 12: Show your larger clients/prospects how to “unbook” benefits related reserves from their balance sheets. If your client/prospect is large enough to self-insure their healthplan, they are required every year to book an IBNR increment (“incurred but not reported reserve” for claims) to finance run-out liability in the pipeline if/when the plan were to be terminated or if it were to convert back to a fully insured approach. Typically the IBNR on the balance sheet will be somewhere between 6 and 12 weeks worth of the most recent year’s paid claims adjusted forward by an annual inflation factor. Unless the size of the plan expenditures is shrinking due to participation reductions and/or significant plan design modifications, the total IBNR will be an ever increasing number. This causes a high degree of frustration with many CFO’s and auditors (i.e., the latter in the case of CFO’s who try to short-fund the reserve with weak justifications).

• There is an optimum trade-off between providing an incentive to certain classes of employees to leave a qualified group healtplan and the remaining risk pool
• Care needs to be used not to gut the qualified group healthplan of young, healthy participants, skewing the costs upward for remaining participants and putting the qualified group healthplan into what is called “the death spiral” in the industry
• Proper care and structure can redirect participants out of the qualified group healthplan and into individual policies in an advantageous manner via the HRA approach
• For every participant eliminated from the qualified group healthplan there is an associated reduction in the required IBNR level on the balance sheet without losing the business expense deduction of the prior group insurance premium contribution
• Warning: projections of net participation should be made. If the net qualified group healthplan  average age and/or health is skewed negatively (i.e., higher projected per capita annual claims), a portion of the IBNR savings will be lost

 ∆ Tip 5 of 12: Show clients/prospect how to use new-hire employee tax savings as a competitive hiring and retention tool.

• IRS regs implemented in 2009 allow for payment of premiums for healthcare coverage provided to an employee or spouse from an HRA even if the coverage is not provided by the employer of a new hire per se
• Many new hire employees remain on the COBRA coverage of prior employer (n.b., there are various reasons such as the 2010 65% subsidy, continuity of care with a provider, plan design elements not in the new plan, a prolonged waiting period with new employer plan, etc.)
• Even if there is 30, 60, 90, or 180 day wait to become eligible under new healthplan of client/prospect, HRA/Section 125 plan eligibility and employer contribution can be made immediate, or at least minimized
• COBRA premiums being paid to former employer’s COBRA can be paid tax-free (20-30% cost reduction to new hire depending on individual marginal tax bracket)
• If 90 day wait, the savings to new hire can approach several thousand dollars
• Shows valuable candidate incremental value of joining your client/prospect company versus another
• Note: this same methodology can be used to assist new hire employee with paying Medicare premium tax-free if spouse is aged 65+

 ∆ Tip 6 of 12: Show clients/prospects how to save money while offering health benefits to ALL employees (including those with less than minimum hours for group plan eligibility, part timers, those in extended waiting periods, etc.).

• Increase employee satisfaction in workforce segment that may feel disenfranchised without major employer investment.
• HRA concept can be used for ALL W-2 employees.
• Non-group plan employees can purchase any IRS allowable health product pre-tax from employer HRA contribution.
• Highly applicable to Florida hospitality industry.
• Increase employee satisfaction & reduce turnover expense
• Some form of health purchase can be made available to every W-2 employee via tax-deductible HRA contribution and Section 125 salary reduction approach.
• Client saves payroll taxes on salary reduction component and take business deduction on HRA contribution.

 ∆ Tip 7 of 12: Show clients/prospect how to allow employees with Medicare aged spouses to use pre-tax money to pay Part B premiums while saving 20-30%.

• Retain valuable experienced employees via Medicare assistance
• Do any of your Florida clients/prospects have employees with Medicare age spouses… more than likely
• Spouse’s Medicare premiums, and other out-of-pocket expenses, can be paid with pre-tax dollars via an HRA approach
• No HRA contribution or too little… the Section 125 component can be used for salary reduction for the balance.
• Employer receives payroll tax savings on the reduced salary amounts

 ∆ Tip 8 of 12: Show clients/prospects how to use an HRA approach as a solution which allows class differentiation in compliance with all new PPACA Section 105(h) non-discrimination regulations.

• Your clients/prospects are likely receiving mixed signals on the Section 105(h) non-discrimination requirements of PPACA following the 9/23/2010 implementation date
• “How do we provided different medical benefits for different types of employees now?” will be the question
• Many broker/consultants are telling them it just can’t be done anymore
• By carefully classing HRA contributions, employers can effectively provide different benefit levels to different classes of employees

 ∆ Tip 9 of 12: Show clients/prospects how to allow employee to use pre-tax money while reducing client/prospect payroll via salary reduction methodology

• How many employees on your client/prospect’s payroll already carry individual health policies or are presently using after-tax money to pay out-of-pocket expenses on a spouse’s plan?
• Employee saves marginal tax bracket amount and employer saves FICA when salary reduction is employed
• Win-Win for employers and employees when using pre-tax money
• Even if your client/prospect has no interest in contributing new funds into an HRA for employees presently not participating in a health plan, show prospect/client how the Section 125 payroll deduction portion can still be used to save FICA and other payroll driven charges (e.g., workman’s compensation insurance premiums running off total payroll)

∆ Tip 10 of 12: Show clients/prospects how to reduce negative employee morale among those employees who feel disenfranchised when not using employer sponsored healthplan.

• When employees see peers utilizing the employer paid portion of medical when they can’t or don’t for some reason, there is a negative impact on performance.
• Show client/prospects how this can be mitigated
• Do client/prospects have any dental or vision only participants in benefit plan feeling disenfranchised because they don’t/can’t use employer medical plan contribution dollars
• Negative morale might not be stated but is often right under the surface effecting performance
• Show client/prospects how employees can use salary reduced dollars for premium elsewhere (e.g., spouse plan, alternative voluntary benefits, etc.) while saving payroll taxes on salary reduction amounts
• Employee allowed to use medical contribution of client/prospect to buy any other IRS allowed health product

∆ Bonus Tip: CPAs can guide clients/prospects in solving management Issues via HRAs. Provide technical guidance to your clients/prospects on just how broadly HRAs can be used to address management issues. Note: reimbursable premiums and other expenses are much more expansive than individual policy or group premiums. IRS Pubs 969 and 502, as well as IRC Section 213(d), provide more info. Also, the Section 125 Proposed Treasury Regulations published in the Federal Register on August 6, 2007 (finalized) provide information on the purchase of individual health policies via an HRA/Section 125 approach beginning in 2009. This link is very individual medical policy oriented. Note: CPAs can assist client/prospect CFOs and HR VPs with solutions to broader challenges. IRS regs expanded to support these approaches. Further research: see recent 3M Corporation announcement of future use of HRA approach to satisfy retiree healthcare obligations (i.e., contribution into HRA and retiree individual purchase of policy and carrier of choice)

∆ Tip 11 of 12:  Show clients/prospects how to reduce the pain of a required qualified group healthplan premium increase on their workforce.

• If client/prospect already has voluntary, 100% employee paid, payroll deduction benefits offered (i.e., AFLAC, Allstate, Colonial, Unum, etc.) offset the pain of a pending medical premium hike by making those benefits 20-30% less expensive for your employee via purchase with pre-tax money
• If no program in place, show how to use strategic placement of voluntary benefits to enhance overall company benefits strategy
• Show incremental value by indicating carrier differentiations
• Note: does not apply to all voluntary benefits
• Approach generally applicable to health related voluntary products allowed per IRS regs
• May facilitate a soft landing for those employees who can no longer afford to participate in qualified group healthplan

∆ Tip 12 of 12:  Show your start-up client/prospects how to save money while making employees happier.

• Many new employers are unaware of the return that can be had with minimum investment
• Does not require high cost or administrative burden to initiate a minimum contribution HRA and allow employees some form of health related benefit purchase
• Payroll tax offsets to employer can often make it a zero cost item
• Can allow start-up employers to attract and retain talent that might be difficult to do otherwise
• Particularly valuable in the hospitality industry where good middle management is attracted to large corporations with full benefit packages and rank and file employees have access to mini-med type plans
• Assists in the reduction of turnover expense with which many start-ups struggle

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To contact BBCG for any product proposals or additional information please click here.

For additional technical information and/or HRA administration proposals, please click here.

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Due to our bonus tip providing various IRS reference citations , our twelve tips are actually a baker’s dozen.

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Please click here for VB proposal.  

 

Why Did BBCG Select AWD As Its Recommended Carrier As Opposed To Alterntives?

 

The Broad Issues

• As an employer are you getting the highest return on the investment you make offering voluntary, payroll deduction, benefits (i.e, “VB”) to your employees?
• Do you have a comprehensive VB strategy in place both for the present and for the post-healthcare reform environment?
• Do you have a mechanism in-place that allows your employees to purchase health-related voluntary products with pre-tax money while saving your company related payroll taxes?

New Dynamics Change the Paradigm

How many people don’t know who “the duck” is at AFLAC? One would think that name recognition alone would dictate  that employee benefits brokers lean towards that carrier in order to maximize the perceived satisfaction of clients’ employees pertaining to the benefits for which they pay 100% themselves. Employees who see, and hear, that advertising icon are likely to believe the carrier to be the industry leader, especially true absent any other significant carrier mass media advertising. In fact it is the undisputed leader. However, it earned that position before VB became such a critical part of an employer’s strategy and when many brokers really didn’t mind a little client erosion around the edges by non-competitive, captive, AFLAC agents.

In the last few years, this segment of the industry has evolved into an entirely new species:

• The carrier players have changed.
• The distribution chain has been altered.
• Corporate strategies are newly attuned to how this piece fits.
• Some group carriers have stuck their toe in the water only to find that they really don’t know how the game is played (n.b., mostly from a marketing expense perspective and less so from a product development perspective). Many of those carriers pulled back but the top group carriers are beginning to recognize that VB is a must in the post-healthcare reform environment.
• Projections of 2x and 3x multiples of individual healthcare policies being sold in 2014 and beyond makes product differentiation (i.e., preventing individual healthcare policies from being perceived as no more than a price-driven homogeneous commodity) a critical strategic consideration for the traditional group carriers.
• It is more than likely that the major group carriers known for their “buy” versus “build” decisions are in various forms of acquisition due diligence as this piece is being written. The histories of Wellpoint, Aetna, CIGNA and UnitedHealthcare are replete with those kind of transactions.
• As the VB business shifts more to brokers, a higher level of carrier evaluation will take place. It will not be sufficient for carriers to just dabble around the edges of this segment of the industry any longer. They will need to be at the state-of-the-art both in terms of product and in terms of distribution support.
• Being unusually candid here, carriers will be forced to eliminate unnecessary interim levels of compensation in the distribution chain (i.e., not pay percentages to non-productive carrier management not actually in the broker chain). Failure on this item will shift broker incentives to the group of  VB carriers which maximize their personal compensation. The lack of competition to date has allowed an odd, and significant, skewing of compensation arrangements. However, it is not a sustainable model as the strategic focus shifts and brokers become more VB knowledgeable.

BBCG’s Thinking

A fundamental question for BBCG as a broker has been “How many VB carriers do we want to represent?” There are dozens in the industry. The top 4 or 5 are well known names. Each has strengths and each has weaknesses. Some employers show an inclination to use their primary group carrier to minimize administrative requirements. Others consider the carrier choice in the same light they have for many years (i.e., the AFLAC model with little return on investment). However, BBCG strongly believes that, concurrent with the sea-change we perceive, VB expertise, both in terms of strategic placement of benefit types and in administration, will be the key determinants of the most forward thinking employers.

Clearly, price will be an issue as well. However, BBCG also believes that competition in the industry segment will draw pricing closer to a mean in apples-to-apples product comparisons.

As a broker, the carrier representation decision becomes one of “value added” for our clients. We recognize that we might lose business by not representing all the carrier players in the way group insurance has traditionally been sold. However, as we seek to deliver the “value added” solution, it is our intent to only use carriers which show the most depth in strategic product placement (i.e., the best mix of products to maximize a desired return on employee benefits investment) and in overall support. Strategic product placement requires not only the greatest number and most innovative mix of products. It also requires a sales staff highly trained to design a complementary offering of VB products as opposed to a wholesale portfolio offering with little profound thinking about the end result.

With the above objectives in mind, BBCG has spent significant time in analyzing the top stand-alone VB carriers in our markets. We will continue to avail ourselves of the group carrier offerings where appropriate. However, for the more discerning employers we have concluded that Allstate Workplace Division (“AWD”) allows us to deliver the greatest “value added” to our clients and we will use that carrier virtually exclusively for that purpose. Some of our thinking:

• The product offerings have the most depth.
• The sales staff has the greatest expertise in terms of strategic placement.
• The administrative support is state-of-the-art.
• Market results (i.e., year over year premium growth) point to their leadership position.
• Conversely, the erosion of market position of alternative carriers points to their weaknesses.
• As a specialty VB carrier AWD also shows staying power, investment, and continued future innovation as opposed to the “toe in the water” approach mentioned above.

The above being said, we recognize the unique strengths of some of the other VB carriers, especially in the area of Life and Disability products. BBCG intends to use such carriers where the scope of the assignment is relatively narrow to those objectives. However, for the broad strategic assignments we see AWD as the carrier which delivers the most value for employers.

We welcome all questions and inquiries.  Please click here to request a VB proposal or strategic placement meeting with BBCG and an AWD representative.


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Quick Jump to Presentation

Has group insurance seen its best days? I had to ask myself that today. In 2016 medical underwriting of individual policies will no longer be allowed. There will no longer be uninsurables that get treated differently under group plans than they do under individual policies. Why would an employer continue to stay on the back of a bronco that has been trying to throw it off for 20 years?

If the employer thinks it has a financial incentive to keep the group plan in place, that is likely not true. Changes in the Internal Revenue Code effective in 2009 makes purchase of individual policies with pre-tax HRA salary reduction amounts, as well as pre-tax employer HRA contribution amounts, permissible. The HRA contributions become “defined” in that the employer can fix the amount, if any, per class of employee, often at a level less that group plan levels.  How the employee uses it is entirely employee driven. The employer steps out of the equation for everything except the regulatory framework of a Section 125 HRA approach.  Employees make their own product purchase and just file the required paperwork with the administrator.

This is an exciting new concept about which only a few really knowledgable consultants are assisting employers. Let BBCG show you how this might work for your workforce.  Please click here to open a link to a preseentation from one of our strategic partners which is a nationally recognized leader in the implementation of this concept.

Please note that this concept is not carrier dependent. Employees can buy any healthplan they desire. However, for ease of transition BBCG can make available to the purchasing employees from one up to three individual plan carriers and assist with the purchase process.  For very large employers considering this transition, BBCG would actually put enrollers on site to assist. Note that with 3 carriers, three basic plans, and dozens of variable alternatives within the plans the decision points can exceed 100 for an employee. Using lowest cost as the driver can often be very dangerous for some employees.

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Many employers want to change payroll companies due to cost considerations but feel restrained due to things like a perceived workman’s compensation financing advantage with the large payroll companies. Click here to see the 1st MSC discussion on alternatives  that exist for employers who want to explore more cost-effective approaches.

You can also go directly to BBCG’s earlier discussion on this issue by clicking here.

BBCG has established a strategic relationship with a Sarasota-based company which is an acknowledged leader in the “pay-as-you-go” workman’s compensation financing approach. Employers who are concerned about having to establish new reserves or being subject to audits if they move their payroll services away from a large service company have alternatives about which they may not be aware.

Click here for a comparison of large payroll service company services and costs.

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Click here for informative piece on large payroll company comparisons. 

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