Boca Benefits Consulting Group Inc.

HHS issued rules on what actions would trigger a loss of “grandfathering” status under PPACA Monday, June 14, 2010. Those rules become effective today Thursday, June 17, 2010 concurrent with their publication in the Federal Register. Below is a summary of interpretation of the final interim rules as BBCG understands them. Many employers remain on the fence regarding the trade-off between plan changes flexibility and the accelerated PPACA requirements if “grandfathering” is reqlinquished. HHS esimates indicate that many employers will voluntarily give up “grandfathered” status in return for more control of their plans (versus the additional PPACA compliance requirements).

Changes that will result in loss of grandfathered status:

• Significant cut or reduction in benefits (e.g., elimination of benefits to cover care for a particular condition)
• Increase in co-insurance rates
• Significant increase in cost-sharing co-payment charges (defined as no more than the greater of $5 (indexed annually for medical inflation) or a percentage equal to medical inflation component of CPI plus 15%; estimated to be approximately 19% total currently)
• Significant increase in deductibles (exceeding medical inflation component of CPI plus 15%)
• Significant reduction in employer contributions (exceeding 5% of prior employer contribution)
• Tightening of an existing or adding a new annual dollar limit (unless replacing a lifetime
dollar limit with an annual dollar limit at least as high as the lifetime limit)
• Merger, acquisition or similar business restructuring – if principle purpose is to
cover new individuals under the grandfathered plan
• Switching carriers under an insured plan (unless the insured plan is covered by a collective bargaining agreement. Does not apply to changes in administrators (i.e., TPA’s) for “ASO” (i.e., self-insured Administrative Services Only type plans).
• Moving employees to a grandfathered plan with lesser benefits

Please email us if we can assist with your current brokerage requirements. Note that employers cannot change carrriers under insured plans (including partially self-insured, minimum premium, etc.) without triggering a loss of “grandfathered” status but that the additional PPACA compliance requirements may still be justified if pricing, service, and/or plan provisions under an existing carrier relationship are felt to be inadequate for your needs.

 
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HHS Releases Final Interim Guidance on “Grandfathering”

Today, the Departments of Health & Human Services, Labor, and Treasury issued long-awaited interim final regulations that specify how “grandfathered” status will be defined and maintained. Regulators spelled out which actions or changes will (and will not) cause a plan to lose its “grandfathered” status.

These interim final regulations will still require analysis by carriers, consultants and employers relative to their implications and effect on employer-sponsored healthplan change decisions. We expect substantial industry opinions in the next day or so. HR and benefits professionals should keep a close eye on these developments.

Please contact us via email if you have questions about the interim final regulations. BBCG will be receiving guidance from carriers, and their attorneys, which may be valuable to you.


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Two items about which employers need to be aware as they make healthplan policy decisions:

1. It appears unlikely that the COBRA subsidy will be re-implemented retroactively. There is serious opposition on the part of budget-conscious Democrats in Congress to extend the subsidy, making its passage problematic. At least for the time being, those going into a COBRA status need to be charged the full amount. In the unlikely event that the subsidy is retroactively implemented, COBRA participants can be reimbursed.

2. It is critical that employers keep up to date on rules that are about to be promulgated relative to what changes are allowable relative to retaining the “grandfathered” status of their existing employer-sponsored plans. Plan changes that add cost or reduce benefits to employees may cause a plan to loose its “grandfathered” status thus making it required to immediately abide by all PPACA provisions (i.e., as opposed to the 2014 statutory date). Information on these rules will likely be public shortly.


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If you are an employer or senior management person trying to keep up with the provisions of PPACA, you are likely very frustrated as are many others. It is a moving target with interpretations and interim rules emerging almost daily. I noted in today’s St. Pete Times comments made following a seminar hosted by the Tampa Chamber on the details of PPACA. Even the normally informed “experts” are a little behind the curve and major employers are struggling with decisions due to incomplete guidance.

CIGNA has been holding a series of web meetings hosted by both their own employees and outside experts. The last one had two attorneys who specialize in PPACA as presenters and who were excellent in terms of their level of knowledge and current information. Following the presentation, a web conference operator moderates individual telephone questions directly to the presenters for specific questions and answers.

You do not need to be a CIGNA client to take advantage of this resource. Even if you just “lurk” without asking any questions, you will be brought up to speed on many details that might not otherwise be available to you. BBCG encourages you to register via the below link and join the web meeting at 2 P.M. June 17, 2010.

Click here for the CIGNA registration web page and link to additional health reform information available from CIGNA.


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United Healthcare’s “UnitedHealthOne” web site is down right now. Guess you guys overwhelmed them with quote requests! The auto quote function on http://bocabenefits.com/ind_health.htm won’t work until they have their scripts up and running again.

If you are attempting to get an individual healthcare quote, please re-try later.


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Below is link to excellent National Association of Insurance Commissioners “Frequently Asked Questions” resource relative to the specfics of PPACA (i.e., 2010 health care reform statute). It is segmented by Consumers, Employers and Seniors.

Click here for link.

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CIGNA is hosting an educational teleconference on the subject of early implementation of the “To Age 26” provision of PPACA. Valuable for all employers sponsoring employee health plans (i.e., both insured and self-funded). Possibly broker and CIGNA client oriented. However, pertinent to all regardless of present carrier and/or TPA.

CIGNA teleconference registration link.

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Below are two links to resources provided by the U.S.  Department of Health and Human Services in regard to the new “To Age 26” provisions of PPACA. Important reading for graduating college seniors, parents and other adult children less than 26 years of age.

HHS Frequently Asked Questions

HHS fact sheet

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United Healthcare announced that it has agreed to the White House’s request to provide coverage for graduating college seniors under the “To Age 26” provision of PPACA (i.e.,  2010 health reform act). See below excerpt from announcement. Click here for full broker announcement.

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On April 19 we (sic) announced that we will work with customers that wish to extend the health coverage that graduating college students currently have under their parents’ plans. As a result, we are mailing letters beginning May 5 to all fully insured customers* regarding our graduate coverage initiative.  The mailing includes the Customer Notice, Letter and FAQ and Opt-Out form posted above.

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Following on CIGNA’s earlier announcement this week regarding early implementation of the PPACA “to age 26” provision, CIGNA has announced today that they will also implement early the “anti-rescission” provisions of PPACA prior to the statutory requirement of 9/23/2010. CIGNA has announced they will make the policy change effective 5/1/2010.

It would appear that CIGNA is attempting to capture the public relations high ground on these decisions relative to their healthcare insurance competitors. However, these are relatively easy changes to effect and will not substantially alter the competitive balance as other major carriers make similar decisions to implement certain PPACA provisions early.

Below Excerpt from CIGNA Press Release:

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CIGNA’s business practices are already compliant with the suggested reforms that are to be implemented on September 23, 2010. CIGNA is confirming that it will not rescind the coverage of any premium-paying customer except in cases of deliberate fraud or intentional misrepresentations of material facts. CIGNA will also institute a policy of third party review if a rescission is to be made.

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Click here for full press release.


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