COOP Health Insurance...Alert!

Section 1322 of the Affordable Care Act (ACA) allowed for the establishment of "consumer operated and oriented plans" or COOPs.  Bolstering the ACA's goal of expanded health insurance coverage, and borrowing from the agricultural industry's adoption of COOPs in the 1920's, twenty-four COOPs were approved and funded by the federal government.  Specifically, the fed awarded nearly $2 billion to the 24 approved COOPs operating in 24 different states.  In theory, the COOPs would bring more competition and choice into the market, which is a welcome change from the hundreds of insurers who have abandoned the health insurance market over the last several years (see Metropolitan Life, Travelers, NY Life, Prudential, Principal, American Chambers Life, and Mutual of Omaha to name just a few).  And if not for funding cuts, and a significant reduction of the originally proposed $6 billion funding allocation, there would likely be even more COOPs in existence. 

To access the complete article, click - https://www.smstevensandassociates.com/ResourceLibrary/tabid/192/Default.aspx

Narrow Networks...Healthcare Buyers Beware!

In the current, post Affordable Care Act (ACA) world, the term - “narrow network” – is often heard, and at times, is a strategy deployed by employers and insurers.  There are a variety of other ways to describe narrow networks, such as - carve out network; exclusive provider network; select network; tiered network…you get the idea.  From a covered member's standpoint, this strategy involves limiting the number of contracted providers plan members can seek care from, and in return, receive the best benefits, and lowest out of pocket costs.  From the standpoint of the insurer or employer, narrow networks mitigate risk and reduce expenses.  Readers who have been around the healthcare scene since the eighties might recall the original introduction of narrow networks, albeit presented at the time as “HMO Lite”;  “a PPO/HMO hybrid”; or more commonly –  “exclusive provider organization”, replete with its very own acronym  - EPO! 

To access the complete article, click - https://www.smstevensandassociates.com/ResourceLibrary/tabid/192/Default.aspx

The ACA and Newton's 3rd Law of Motion

Sir Isaac Newton’s Third Law of Motion taught us that “for every action, there is an equal and opposite reaction”.  As we near the end of the fourth full year of the [partial] roll out of The Affordable Care Act /Obamacare, it has become increasingly more challenging for people to differentiate “action” from the “equal and opposite reaction”.  Put another way, some of the things we’re experiencing, required by the ACA, are directly attributable to the law itself (call these “actions”).  And then there are things we’re seeing that are the result of the many requirements, mandates, fees/taxes, expansions associated with the ACA (call these “equal and opposite reactions”).   This will all make more sense when you see the chart at the end of this article.

To access the complete article, click - https://www.smstevensandassociates.com/ResourceLibrary/tabid/192/Default.aspx

Ebola ~ Just the Facts

Readers of this blog (soon to be "resource library") typically find health INSURANCE, FUNDING, and FINANCING issues addressed here.  But occasionally, health CARE issues come to light which I feel compelled to address.  With all the media coverage and confusion surrounding the recent outbreak of the Ebola virus, I decided to attempt to clarify some important facts.  My primary source of information for this post is the Douglas County Health Department (Douglas County, Nebraska), which under the direction of Dr. Adi Pour, does a fantastic job of data mining and educating, among other things.  (See http://www.douglascountyhealth.com )

The Ebola virus was first discovered in 1976 in the Ebola River, which is located in a region of Africa now known as the Democratic Republic of the Congo in lower, central Africa.  Although the virus has been found in several African countries since its initial outbreak, as of the time of this blog post, there are four (4) countries in the western region that have experienced outbreaks - Guinea, Liberia, Nigeria, and Sierra Leone.  The current, 2014 outbreak is the largest in history, and the first to occur in west Africa.

Perhaps the most misunderstood, and in some instances, incorrectly reported aspect of Ebola, is how it is spread.  It is NOT spread via air or water, but rather through direct contact with someone who: a. is infected with the virus; and b. is also experiencing symptoms.  Clearly health care workers are at the greatest risk of contracting the virus, as evidenced by the recent reporting infected health care workers in Dallas, TX. The U.S. Centers for Disease Control and Prevention (CDC) are taking very deliberate and focused measures to mitigate, if not prevent Ebola and for that matter all infectious diseases, from arriving and spreading throughout the U.S.

IMPORTANT: CDC Director - Thomas Friedan - specifically addressed rumors relative to the ability of the Ebola virus to spread through the air, which have actually "fueled" the rumor mill.
On 10/7/14, he said:
"The rate of change [with Ebola] is slower than most viruses, and most viruses don't change how they spread.  That is not to say it's impossible that it could change [to become airborne].  That would be the worst-case scenario.  We would know that by looking at...what is happening in Africa.  That is why we have scientists from the CDC on the ground tracking that."

In addition to how the Ebola is (and is not) spread, here are some of the more relevant and pertinent facts concerning Ebola, gleaned from the aforementioned source:

• An individual that recovers from being infected can no longer spread the virus.  However, the virus can survive for up to three months in semen.
• Only mammals have shown the propensity to be infected with, and spread, Ebola.  Specifically at this point in time - humans, apes, monkeys, and bats.  Mosquito's and other insects, at this point, are not able to transmit the Ebola virus.
• The CDC and the U.S. Fish and Wildlife Service have specific protocols in place to prevent the Ebola virus from coming into the U.S. via non-human primates and bats.  The greater challenge, as we now know, is dealing with humans arriving on U.S. soil, who have contracted the virus.
• The CDC is working with all U.S. hospitals on establishing and implementing the proper infection control measures to control the continued spread of the Ebola virus.
• Since all U.S. citizens have the right to return to the U.S. for treatment of any contacted disease/disorder, we simply can not completely prevent infected citizens from re-entering the country.  For this reason, the CDC has taken specific and deliberate actions, including raising the travel alert level to Level 3 (i.e., travelers incur high risk of traveling to the four identified, west African countries, and are advised against nonessential travel to those locations).
• The CDC's Emergency Operations Center (EOC) has been activated to assist with the coordination, communication, monitoring, and management of this current challenge.

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ACA's Transitional Reinsurance Fee/Tax

Self funded health plans face a rapidly approaching compliance deadline of January 15, 2015 relative to the Affordable Care Act's so called "transitional reinsurance fee".  A previous post addressed the various reinsurance (or bailout) programs devised in the ACA (click - http://sstevenshealthcare.blogspot.com/2014/01/acas-insurance-company-bailouts.html). 
These programs are sometimes referred to as the "Three R's", which are:

1. Reinsurance Program
2. Risk Corridor
3. Risk Adjustment

The first of these reinsurance/bailout programs - the [temporary] reinsurance program - is funded by virtually ALL health insurance plans (e.g., individual, group, fully insured, self funded) through the assessment of a fee/tax.  Fully insured plans owe the tax, but do not have to worry about counting/collecting/remitting.  Self funded plans however, are responsible for all of the aforementioned.  So, here's the scoop on determining the amount of your organization's tax, along with when, and how to submit it....

For 2014, the amount of the transitional reinsurance fee is $63 per covered MEMBER, per year (PM/PY). Note that this breaks down to $5.25 per member, per month. Also note the term "member" includes ALL covered members of the plan...employee, spouse, and children. In 2015 the amount reduces to $44 PM/PY, and the estimated amount for 2016 is $25-$30 PM/PY.  

IMPORTANT: Affected employers are required to report the number of covered/affected member lives by NOVEMBER 15, 2014 via - https://pay.gov/public/home
Training sessions designed to assist employers are being offered/provided by CMS through November 15, 2014.  To find out more about these sessions, click - https://www.regtap.info/

Affected employers have the option of paying their 2014 fee in installments, or in a lump sum.  If the later, the required amount is due no later than January 15, 2015.  If the former, the first installment (of $52.50 PM/PY) is due no later than January 15, 2015; and the second installment (of $10.50 PM/PY) is due no later than November 15, 2015.

The ACA's regulations allow for a variety of methods to determine each affected employers PM/PY fee.  The simplest of these methods is the so called "snapshot method".   Using this method, the average number of covered members on which to base the fee is found by adding the total number of covered employees on January 1, April 1, and July 1 of each year, dividing that number by three, and multiplying by the appropriate fee amount.  For example, for 2014:

• Lump Sum: January 1: 75 members + April 1: 80 members + July 1: 90 members = 245/3 = 82 x $63 = $5,166 transitional reinsurance fee due by January 15, 2015.
• Installment: January 1: 75 members + April 1: 80 members + July 1: 90 members = 245/3 = 82 x $52.50 = $4,305 transitional reinsurance fee installment no. 1, due by January 15, 2015.  January 1: 75 members + April 1: 80 members + July 1: 90 members = 245/3 = 82 x $10.50 = $861 transitional reinsurance fee installment no. 2, due by November 15, 2015.

The federal government promises a "streamlined membership and contribution" process, through which employer's remit their transitional reinsurance fee.  A dedicated website (click - https://pay.gov/public/home) provides a secure, web based portal employers use to report and submit their required tax.  

For a more detailed overview of the transitional reinsurance fee, and the process of remitting the required fee/tax, click here - http://www.cigna.com/assets/docs/about-cigna/informed-on-reform/reinsurance-assessment-fact-sheet.pdf

 

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ACA's Health Plan Identifier Requirement

As the old saying goes, "the devil is in the details", and the Affordable Care Act (ACA) has its fair share of DETAILS.  Among the rapidly approaching compliance deadlines for many employers is requesting/obtaining a ten-digit Health Plan Identifier or HPID.   While ALL employers offering health insurance plans must comply with this requirement, the due date for obtaining the ID, along with determining who is responsible for obtaining it varies based on a couple of factors.  Here's an overview of the whole HPID matter...

To access the complete article, click - https://www.smstevensandassociates.com/ResourceLibrary/tabid/192/Default.aspx

Open Enrollment Best Practices

As we approach the labor day holiday, human resources officials, brokers, consultants, and others begin to think not as much about the end of summer, but rather, the approaching OPEN ENROLLMENT SEASON!  Before we know it, that special time of the year will be upon us.  Having been involved with so many open enrollments over the years, as an insurance company executive, third party administrator, wholesaler, consultant, and retailer/broker, I have accumulated some insight as to what employees/enrollees should be considering during this important time of the year.  Call these my "open enrollment best practices", or, put another way, the things enrollees/employees should consider as they enter open enrollment season...

1. When reviewing health insurance options (and for that matter, dental, vision, life insurance, etc.), always annualize the premium amounts presented/offered.  Most of the time, the employee/enrollee is going to be enrolled for a full, 12 month period, so it just makes sense to look at financial responsibility on an annual basis.  Plus, plan related deductibles and out of pocket accumulations generally refresh after a period of 12 months.
2. Consider ALL available health insurance options.  It might turn out that coverage offered by a particular employer to a particular employee may not be the best option.  There are other options worthy of consideration, such as:
• Spouse's employer plan
• Medicare (with associated supplemental coverage(s)/Medicare Advantage
• Individual coverage purchased on the private market
• Individual coverage purchased on the public exchange/marketplace
• Veteran's Administration
• Tricare
3. Don't just focus on one aspect of the coverage (e.g., copays for office visits, the deductible, the coinsurance percentage, etc.).  Rather, tally up the entire OUT OF POCKET expense of the option(s), and consider the plan(s) that make the most sense for the individual and/or families health care needs.  If the individual/family uses little to no health care services, the plan offering with the lowest premium makes more sense.  Alternatively, the individual/family that uses a fair amount of health care services should consider the plan with the lowest potential out of pocket limit.  Ask if there's a decision support tool available which helps employees make a more informed decision of coverage based on their historical use of health care services.  
4. Take into account the offering of dollars to be used for health care expenses that insurance doesn't cover, or for use meeting deductible/copay/coinsurance obligations.  Sometimes employers offer/fund/provide dollars in multiple spending arrangements.  These usually end in the letter "A", as in HSA...FSA...HRA.
5. Inquire into stipends and assessments that may apply, based on enrollment decisions.  Some employers offer an opt-out or waiver stipend (either post tax, or tax-free through a Flex plan) if an employee opts to waive the coverage offered.  On the flip side, some employers require an assessment (in addition to the premium cost share) for covering a spouse who has coverage available through their employer.  These additional amounts of dollars are significant factors in making open enrollment decisions.
6. If a wellness incentive is offered, it's very important to understand what the requirements are, in addition to the associated rewards/penalties.  There are a myriad different wellness programs being offered, with untold ways of incentivizing (or penalizing!) employees.  Some wellness programs require very little, yet yield a high reward (e.g., premium reduction, HSA contribution, cash reward, etc.).  Others require much, yet provide a marginally small incentive.
7. Many employers offer their employees the opportunity to pay their portion of the premium for health, dental, and vision coverage with pre-tax dollars through a Flex plan (sometimes called a "section 125 plan", or a "cafeteria plan").  This is a great way for employees to reduce their tax obligation, but enrollees need to know that if they take advantage of this offer, they are committed to remaining enrolled in the plans they are paying for with pre-tax dollars, for the entire 12 month period of the Flex plan.  The only way to dis-enroll earlier is to experience a qualifying event.
8. Speaking of Flex plans (and previously, HSA (health savings account) and HRA (health reimbursement arrangement)), these arrangements/accounts offer enrollees outstanding tax benefits, along with the means to pay for lower cost health care.  Employees/enrollees should consider the use of tax preferred dollars available to them in one or more of these "A's", and take full advantage.  Many times I see employees offered both an HSA and a Limited Purpose FSA, and either or both are completely ignored...BY HIGH UTILIZERS!

Have a wonderful Labor Day Holiday...and an even better OPEN ENROLLMENT SEASON!

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ACA Employer Reporting...Continued

A previous post informed about an upcoming (voluntary in 2015; mandatory in 2016) Affordable Care Act (ACA) compliance requirement requiring employers (small and large) and health insurers to report on health insurance coverage offered to employees. 
(See - http://sstevenshealthcare.blogspot.com/2014/03/aca-employer-reporting-requirements.html )

Recently the IRS released draft versions of various forms that employers will need to disclose detailed information to both their employees and the IRS.  The purpose of the reporting is to assist the federal government in enforcing the ACA's individual mandate, employer mandate, and premium subsidy provisions.

To access the complete article, click - https://www.smstevensandassociates.com/ResourceLibrary/tabid/192/Default.aspx

ACA Changes, Repeals, Modifications, Clarifications...Thus Far

Readers and health care stakeholders may find it interesting (if not frustrating), that as of the date of this blog post (August 6, 2014) there have been a grand total of 42 changes* made to the Affordable Care Act (ACA) since its signing into law on March 23, 2010.  Furthermore, the changes have not originated from a single source; nor have the changes been influenced/encouraged by a single political party.  The fact is, of the 42 changes to date, 24 have been made unilaterally by the President; 16 resulting from acts of Congress; and perhaps the most notable - 2 - by the Supreme Court of the United States (SCOTUS).

To access the complete article, click- https://www.smstevensandassociates.com/ResourceLibrary/tabid/192/Default.aspx

ACA Split Court Decision/Subsidy Eligibility

 

On July 22, 2014, two separate U.S. appellate courts issued contrasting rulings pertaining to a key aspect of the Affordable Care Act (ACA).  The issue at hand is language contained in the 2,700 page law addressing eligibility for subsidies (or tax credits) for those unable to afford the premiums for INDIVIDUAL health insurance.  Specifically, the cases hinge of just four words - "...established by the state", or in its entirety - "[ACA] subsidies shall be available to persons who purchase health insurance in an exchange established by the state". 

Since the overwhelming majority of states opted to defer to a federal or hybrid federal/state exchange (36) the language presented a significant problem.  In effect, the language meant that only eligible individuals residing in one of the 14 states that opted to establish a state based exchange would be eligible for subsidies. The following graphic indicates (in white) those states that actually formed STATE based exchanges:

 To access the complete article, click - https://www.smstevensandassociates.com/ResourceLibrary/tabid/192/Default.aspx

PCORI/CERF Requirement...Year 2

A little over a year ago, I posted a blog addressing the Affordable Care Act's (ACA) - Patient Centered Outcomes Research Institute (PCORI) fee requirement, also referred to as the Comparative Effectiveness Research Fee (CERF).  Click here to access this post - http://sstevenshealthcare.blogspot.com/2013/06/to-pcori-feeor-not-to-fee-that-is.html
Last year, affected plans were required to remit a fee equal to $1 per plan participant.  This year, affected plans owe $2 per plan participant, based on their plan date.  Since last year's PCORI/CERF related post addressed the "who" and "what" of this particular ACA requirement; this post will address the "how", as in how to calculate the average number of affected lives, and then calculate and remit the applicable fee.

Plans that are fully insured (as opposed to partially or fully self funded) generally do not have to worry about calculating or remitting the fee.  Insurance companies are taking care of this ACA compliance task.  Employers that have fully insured plans who are curious about the direct cost impact of this fee on their premium can calculate their cost using any one of four prescribed methods:

1. Actual Count
2. Snapshot
3. Member Months
4. State Form

If interested, click here for the specific details on each of these approved PCORI/CERF counting methods - http://www.irs.gov/uac/Newsroom/Patient-Centered-Outcomes-Research-Institute-Fee

IMPORTANT
Health insurance plans that are partially or fully self funded (including HRAs and some FSAs) generally must calculate and remit their PCORI/CERF fee themselves.  Since the fee is remitted on IRS form 720, a self funded plan's administrator is not able to take care of this requirement on the client's behalf.  Here are the approved alternative methods of calculating the appropriate PCORI/CERF fee for self funded plans:

1. Actual Count Method: Add the total number of covered lives (members, not employees) for each day of the plan year and divide that total by the total number of days in the plan year.
2. Snapshot Method: Add the total number of covered lives (members, not employees) on a particular date during the first, second, and third month of each quarter, and divide that total by three.  For example, using January 1, April 1, and July 1 as the calculation dates, assuming there were 150, 155, and 159 covered lives on each respective date, the calculation would be 150 + 155 + 159 = 464/3 = 155 x $2 = $310.
3. Form 5500 Method: (Note, from my experience, this is the simplest and lowest cost result method of the three.) Add the number of covered employees (sometimes referred to as participants or subscribers) at the beginning of the year, as indicated on IRS form 5500, to the number of covered employees at the end of the plan year.  For example, if there were 100 employees on January 1, and 150 employees on December 31, the calculation would be 100 + 150 = 250 x $2 = $500.

To access the IRS' final regulations addressing PCORI/CERF, click here - http://www.gpo.gov/fdsys/pkg/FR-2012-12-06/pdf/2012-29325.pdf

Remember, this fee is due and filed with the second quarter IRS form 720, no later than July 31st of the calendar year immediately following the last day of the policy year or plan year to which the fee applies.  For the majority of affected plans which start/renew on January 1, 2013 through December 31, 2013, the fee is due by July 31, 2014.

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ACA's Future

Here are a few questions often posed pertaining to the Affordable Care Act (ACA): 

1. "What does the future of health care/health insurance look like, once the ACA is fully implemented"?
2. "Will the ACA result in significantly fewer or more uninsured individuals"?
3.  "After four years, what do we know about the affect of the ACA on premiums"?

This week's post offers my overall response, and associated concerns, related to these three, and perhaps other questions...

To access the complete article, click - https://smstevensandassociates.com/ResourceLibrary/tabid/192/Default.aspx

Supreme Court Ruling/Contraception Coverage

This week (June 30, 2014) the Supreme Court ruled in favor of plaintiffs - Hobby Lobby, Mardel, and Conestoga Wood Specialties - in their respective challenges to the Affordable Care Act's (ACA) contraception mandate.  The basis for their cases was simple in nature, but sweeping in scope, as there are over 90 similar cases currently pending in courts around the country.  The court's decision was quickly followed by a tremendous amount of media coverage, some of which is patently false and misleading.  Here's an overview of what we know at this point...

To access the complete article, click - https://smstevensandassociates.com/ResourceLibrary/tabid/192/Default.aspx

HIPAA - Forgotten But Not Gone

With so much emphasis being placed on Affordable Care Act (ACA) compliance these days, some folks have gradually (and frighteningly) forgotten about the ACA's "older brother" - the Health Insurance Portability and Accountability Act (HIPAA).  Several ACA provisions supersede or expand upon HIPAA provisions that went into effect on and after January 1, 1997 (e.g., preexisting condition limitations, guaranteed issue/renewability, certificates of creditable coverage, etc.).  However, the ACA did virtually nothing to change the privacy and security aspects of HIPAA, which are not only still in effect, but carry stiff fines and penalties for non-compliance.

HIPAA created a new acronym - PHI - which stands for protected health information.  And among the many requirements created by HIPAA, perhaps none are more important than those addressing the request, disclosure and use of PHI by "covered entities" and "business associates".  HIPAA privacy rules also create rights for individuals to access, review, and amend their PHI.  Readers are likely familiar with the seemingly constant flow of HIPAA disclosure notices.  I want to provide a considerable amount of caution in this week's post, relative to HIPAA and PHI:

To access the complete article, click - https://smstevensandassociates.com/ResourceLibrary/tabid/192/Default.aspx

ACA Transition Relief - Employer Mandate

In February of this year (2014), I provided an overview of the IRS' final regulations pertaining to the Affordable Care Act's (ACA) employer mandate.
Since this is such a confusing provision of the ACA, to say nothing of the fact that there have been not one, but two separate delays of this provision, I decided to recap some of the more pertinent aspects of the final regulations and associated transitional relief.

To access the complete article and related links, click - https://smstevensandassociates.com/ResourceLibrary/tabid/192/Default.aspx

Prescription Drugs - Health Care's Low Hanging Fruit

There is an often overused metaphor equating things easily obtained with "low hanging fruit".  And in the world of health care and consumer driven health care (CDH), there is perhaps NO lower hanging fruit to be had than prescription drugs.  I would further submit that few if any other product category in our entire economy has the sheer number of FREE...DISCOUNTED...REDUCED...SAMPLE offers connected to it, by a variety of constituencies including - manufacturers, distributors, insurers and employers - than do prescription drugs.  But do the very people these offers of "low hanging fruit" are directed toward understand the "what", "why", or even "where" associated with them?

To access the complete article, click - https://smstevensandassociates.com/ResourceLibrary/tabid/192/Default.aspx

Employers Reimbursing Employees for Individual Coverage

Recently, the IRS issued guidance which places harsh penalties on employers that deploy the strategy of "dumping" employees into the Individual health insurance marketplace.  The guidance followed the White House's objection to the idea of allowing employers the ability to provide employees with a lump sum of money with which to buy individual insurance on the exchange/marketplace.  This builds on guidance released last year from the Department of Labor (DOL) which was more broad in scope.  A previous blog post addressed the DOL guidance, which effectively "killed" the ability to use tax preferred funds from HRAs and FSAs to fund Individual health insurance premiums, regardless of the source of such coverage.
The recent ruling and associated guidance is short and sweet.  Here's the scoop...

To access the complete article, click - https://smstevensandassociates.com/ResourceLibrary/tabid/192/Default.aspx

COBRA, ACA, and Special Enrollment Rights

With the seemingly endless flow of guidance, updates, notices, and delays swirling about relative to the Affordable Care Act (ACA),  a rather important piece of guidance may have been overlooked.  Issued jointly by the Department of Labor (DOL) and Health and Human Services (HHS) earlier this month (May 2, 2014), this guidance provides an opportunity for individuals enrolled in COBRA coverage the option to dis-enroll in their COBRA coverage, and enroll in potentially lower cost individual health insurance coverage, FOR A LIMITED TIME.  (Click - http://www.cms.gov/CCIIO/Resources/Regulations-and-Guidance/Downloads/SEP-and-hardship-FAQ-5-1-2014.pdf )
This week's post addresses this guidance and provides additional information related to the transection of COBRA and the ACA.

To access the complete article, click - https://smstevensandassociates.com/ResourceLibrary/tabid/192/Default.aspx

HSA Updates and Advanced Guidance

The Internal Revenue Service (IRS) has announced the Health Savings Account (HSA) maximum contribution amounts, and qualified high deductible health plan (QHDHP) deductible and out of pocket limits for 2015.  Since I have provided basic guidance on "all things HSA" in a previous post (see - http://sstevenshealthcare.blogspot.com/2013/10/health-savings-accounts-hsas.html ), I thought I would provide some advanced HSA guidance in this week's blog, along with the recently announced 2015 IRS maximums.

To access the complete article, click - https://smstevensandassociates.com/ResourceLibrary/tabid/192/Default.aspx

CDHPs Affect on Health Care Spending

Ordinarily, I try to couple a picture with the content of my post, creating a theme of sorts.  This week, my selected picture IS the essence of the blog post.  The picture is a chart provided by the Centers for Medicare and Medicaid Services (CMS) showing the slowing of health care spending from 2002 to 2013, by nearly 90%.  A previous blog post addressed this topic (click - http://sstevenshealthcare.blogspot.com/2014/01/whats-causing-health-care-spending-to.html)
One of the factors contributing to the slow down in health care spending cited in this post (titled appropriately - What's Causing Health Care Spending to Slow?) is the growth in popularity and implementation of so called high deductible health plans with accompanying tax preferred spending accounts.  Better known as Consumer Driven Health Plans, or CDHPs, these plans affect both the demand and supply of health care, and as time, data, and logic has now proven, THESE PLANS REDUCE HEALTH CARE COSTS WITHOUT COMPROMISING CARE!

To access the complete article, click - https://smstevensandassociates.com/ResourceLibrary/tabid/192/Default.aspx

Understanding the Two Separate ACA Delays

 

French novelist and critic - Jean-Baptiste Alphonse Karr - famously said (originally in French and translated to English in the mid 1800's) - "the more things change, the more they remain the same".  Based on recent news in Nebraska, relative to the roll out of the Affordable Care Act (ACA), aka Obamacare, I am going to reverse Mr. Alphonse Karr's famous quote to say - "the more things remain the same, the more they change"!  If you're not in Nebraska, keep reading because this week's blog post addresses the allowance of what now amounts to a nearly three year delay of several key provisions* of the ACA...for some.

To access the complete article, click - https://smstevensandassociates.com/ResourceLibrary/tabid/192/Default.aspx

CDH - Shifting Behavior Rather Than Costs

Since the "birth" of so called Consumer Driven Health Plans (CDHP) in the mid 90's, opponents have argued that CDHP's merely shift health care related costs from employer to employee. This is simply not the case, and health insurer/administrator Cigna's eighth annual "Choice Fund Experience Study" offers quite the opposing view, buttressed by empirically derived facts.  Over the course of CDH's evolution, I have learned a great deal from many of the pioneers and trailblazers of CDH, including the "father of HSAs" (John Goodman), "Mr. HSA" (Roy Ramthun), and the "Godmother of CDH" (Regina Herzlinger).  And studies like Cigna's provide sound data and efficacy to once again advance the fact that CDH LOWERS HEATH CARE COSTS without sacrificing care or coverage!

The study compares actual claims experience from 3.6 million Cigna customers enrolled in CDH, traditional PPO, and HMO health plans.  To access a summary of findings, click here - http://newsroom.cigna.com/images/9022/874630_ExecutiveSummary_FINAL.pdf
Here are some interesting, if not compelling highlights...

To access the complete article, click - https://smstevensandassociates.com/ResourceLibrary/tabid/192/Default.aspx

What Employees Should Know About the ACA

I am often asked by HR professionals, CEO's, CFO's, Executive Directors, etc. the following question - "what should I be telling my employees about the Affordable Care Act (ACA)"?  Between the 2,700 pages of the actual law, and the thousands of pages of regulations and guidance released to date, the question is very relevant, and extremely important.  While I firmly believe folks occupying roles with the aforementioned titles should receive a thorough initial overview of the ACA, and ongoing guidance and updates; rank and file employees need only get the absolute critical aspects.  So you might ask - "what are the critical aspects"?

My list of employee-centric, critical aspects is based on the following questions/criteria:

To access the complete article, click - https://smstevensandassociates.com/ResourceLibrary/tabid/192/Default.aspx

Workplace Wellness Programs

Within just the past decade or so, Workplace Wellness has become an industry within an industry.  In fact, as a benefits broker/consultant, I get as many calls from Wellness program vendors as I do from insurance companies, seeking new client opportunities.  Recently I came upon an article that made some interesting points relative to Workplace Wellness programs, and the potential outlay of employer dollars in the interest of reducing health care related claims costs.  Here are some thoughts for readers and stakeholders to ponder:

• On average, U.S. citizens consume about 2,700 calories per day.
• Healthy food costs significantly more than unhealthy food.
• The per calorie difference in the cost of healthy versus unhealthy food is significant.  Just look at these examples:
  • Tortilla chips, hot dogs and cheese curls - $.001/calorie
  • Ground beef and Italian sausage - $.003/calorie
  • Apples and pears - $.007/calorie
  • Blueberries, grapes, and cucumbers - $.01/calorie (10 times the chips, dogs, and curls!)
  • Fresh vegetables - $.02/calorie (20 times the chips, dogs, and curls!)
• On average the difference between the healthy and unhealthy food is about $.33 or 1/3 of a cent.  If you multiply this $.33 x the average daily calorie intake of 2,700, it comes to $9 more, per person, per day to eat healthier.
• The annual difference in eating healthy versus unhealthy, based on the previous calculation, amounts to $3,000 per person, per year.  

So one way of looking at structuring a Workplace Wellness Program that provides the appropriate incentive to employees (and dependents) to "eat well", would be to compensate for this $3,000 difference, again, per person.  Clearly, such an approach would be neither reasonable or affordable, but it does make you think about one of the major challenges we face as a nation, and as employers offering health insurance benefits. 

Remember, of the $2.7 trillion in U.S. health care spending (in 2012), there are estimates that as much as 75% of this amount is attributable to PREVENTABLE conditions, largely related to certain BEHAVIORS (e.g., eating, drinking, smoking, driving without a seat belt on, etc.).  And one health care economist (Dr. Jonathon Gruber; MIT) estimates that roughly 1/3 of this total outlay ($800 billion) is attributable to unnecessary diagnostic tests, procedures, and extra hospital days.

In conclusion, it benefits all of us to design and implement Workplace Wellness programs that work in conjunction with Consumer Driven Health (CDH) plans, in the interest of helping plan members become better, smarter, and more prudent health care consumers.

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Public Marketplaces/Exchanges Still Open!

Despite numerous reports of the "closing" of the Affordable Care Act's (ACA) public health insurance exchanges/marketplaces on March 31, 2014, THEY'RE ACTUALLY STILL OPEN FOR BUSINESS!  Media reports stating that "the exchanges are closed" are simply inaccurate.  Much like group health insurance plans, ACA marketplace/exchange plans have two (2) enrollment periods:

1. Open Enrollment - which ran from 10/1/13 - 3/31/14 in the inaugural year of the launching of the public marketplaces/exchanges.   IMPORTANT: The Department of Health and Human Services (HHS) announced on March 26, 2014 that it would extend the open enrollment deadline for consumers to enroll in a public marketplace/exchange health insurance plan if they started enrollment before March 31 but weren’t able to complete the application by midnight.; and
2. Special Enrollment - qualified individuals have another opportunity to obtain coverage both on and off the the public marketplaces/exchanges, on a guarantee issue basis, with all the other ACA related provisions (e.g., community rating, 10 essential health benefits, no pre-existing condition limits, etc.).  Such an opportunity, referred to as a "special enrollment period" is triggered by one or more "circumstances", including, but not limited to the following:

• loss of coverage (generally involuntary; the lost coverage must meet the ACA's "minimum essential coverage" guidelines);
• gaining or becoming a dependent through marriage, birth, or adoption;
• becoming a citizen, national or legally present;
• mistake by the marketplace/exchange or the department of Health and Human Services (HHS);
• contract violation by a plan or certain misconduct on the part of a non-Exchange entity providing enrollment assistance or conducting enrollment activities;
• change in eligibility for federal subsidies;
• gaining access to a new qualified health plan due to a permanent move; or
• other exceptional circumstances (defined by the particular State/Federal exchange/marketplace).

Eligible individuals may still purchase subsidized coverage from a Public marketplace/exchange during a special enrollment period. 

Click here for a link to specific guidance relative to special enrollment periods - https://www.healthcare.gov/how-can-i-get-coverage-outside-of-open-enrollment/

Special enrollment periods are generally 60 days from the date of the triggering circumstance or event.  Coverage effective dates follow the rules that apply to open enrollment, which is the first of the month following enrollment made by the 15th of the preceding month.
[Example: coverage applied for between 6/1/14 - 6/15/14 becomes effective 7/1/14.]

And finally -  open enrollment for 2015 will run 11/15/14 - 2/15/15, allowing both new enrollments and changes to existing coverage.  This is a shorter enrollment window of time than was allowed for the 2014 enrollment season.

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