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Archive for the ‘healthcare legislation’ tag

New Feds Guidance on Use of HRA’s and HRP’s [Exchanges Related Info]

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The below info is excerpted from a Zane Benefits information piece published Sunday, Sep 15, 2013.  The entire technical discussion can be accessed at their RSS blog feed by clicking here.  The essence of the discussion is that unlike what some major group insurance carriers have been indicating, newly stuctured HRP’s ( i.e., a limited healthcare reimbursement plan) can be used as the vehicle to shift employees from a group plan to individual purchases on exchanges. Wallgreens is the most recent large company to announce such a shift (click here for info on annoncement today 9/18/2013). IBM and Time Warner have made similar announcements.

[Begin Excerpt] ____________________________

Now, the good news

Employers can still reimburse employees for individual health insurance premiums.

For the first time, the Department of Labor, the Department of Treasury, and Health and Human Services have coordinated to issue formal confirmation that employers are 100% allowed to reimburse individual health insurance premiums tax-free under the tax code. This is a MAJOR positive.

We repeat – employers are still allowed to reimburse employees tax-free for individual health insurance premiums.

 

What is the solution for plan years beginning on or after January 1st, 2014?

For plan years beginning on or after January 1st, 2014, the solution is to adopt a limited Healthcare Reimbursement Plan (HRP), such as ZaneHealth.

The HRP is structured to only reimburse:

  1. Health insurance premiums up to a specified monthly healthcare allowance,
  2. Preventative care as required by PHS Act Section 2713 at 100% without cost-sharing.

This structure ensures the HRP complies with the PHS Act 2711 annual limit requirements and the PHS Act 2713 preventative care requirements as outlined in the Technical Release.

Additionally, care must be taken in the design and administration of the HRP to ensure the plan does not meet the definition of an eligible employer-sponsored plan in IRC Section 5000A and consequently qualify as minimum essential coverage. This ensures employees participating in the HRP are able to receive a tax subsidy via the new health insurance marketplaces assuming they meet additional eligibility criteria.

Conclusion / Next Steps

With the Departments all in agreement, everyone should be excited there is finally a clean, final process for employers to reimburse employees for individual policies that are guaranteed-issue.

Sponsors of stand-alone HRAs should begin preparing to convert their plan to an HRP for plan years beginning after 2014.

Finally, our nation can rid itself of one-size-fits-all employer group health insurance policies that hamper businesses, employees and their families.

[End Excerpt] _____________________________________

 

 

White House Lists Carriers Advancing Age 26 Provision in PPACA

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Below from The White House Blog. See http://www.whitehouse.gov/blog/2010/04/27/more-support-young-adults for a list of carriers voluntarily accelerating the “age 26” provision to make in coincide with 2010 college graduation dates as of the date of this posting. BBCG expects that most all carriers will ultimately agree to this timeline.

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But we knew that some young adults graduating from college this spring could risk losing their health insurance before the provision takes effect, only to be added back onto their parents’ policy the next time their parents’ plan comes up for renewal on or after September 23rd.  That was bad news for families and bad news for insurance companies too.  Removing an individual from a health insurance plan and then adding them back on a few months later takes time, and it costs money.

That’s why on April 19, Health and Human Services Secretary Kathleen Sebelius called on leading insurance companies to begin covering young adults voluntarily before the September 23 implementation date required by the new health reform law.  Early implementation would avoid gaps in coverage for new college graduates and other young adults and save on insurance company administrative costs of dis-enrolling and re-enrolling them between May 2010 and September 23, 2010.   Early enrollment will also enable young, overwhelmingly healthy people who will not engender large insurance costs to stay in the insurance pool.

And we’re pleased to report that the following insurance companies are doing just that:

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Carriers Accelerate PPACA Provision for Age 26 Eligibililty

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We have received communications from both CIGNA and Aetna that they will each be implementing the “to age 26” provisions of the Patient Protection and Affordable Care Act earlier than required by statute (9/23/2010).  The concern stated is the potential for a gap in coverage for those in the 21-26 age group who may be graduating from college and who would otherwise lose eligibility once full-time student status was eliminated.

Both companies are making their eligibility changes effective 6/1/2010.

Although we have not seen announcements from either Blue Cross/Blue Shield or United Healthcare, BBCG is surmising that the changes announced by Aetna and CIGNA have become the new de facto eligibility standard and that the other major healthcare insurers will follow.

Click here for CIGNA announcement. 

Click here for Aetna announcement.

Snapshot of Implications of Passed Healthcare Reform Legislation

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BBCG did not spend a lot of time massaging the below linked file to make it aesthetically pleasing. It summarizes the implications for employer sponsored health plans (i.e., both insured and self-insured). We opted to expedite the posting. Although the House was forced to revisit the reconciliation procedures, the actual gist of the legislation is unlikely to change.

See http://bocabenefits.com/reform_as_passed.pdf for the summary.