mc corvie - healthcare reform: how to get here from there
TRANSCRIPT
Major Plan Design ChangesMajor Plan Design Changes
For plans years beginning after September 23, 2010
(2011 Calendar Year Plans)
Advance Notice of Benefit ChangesAdvance Notice of Benefit Changes
2011
• 60‐day notice required
• Includes changes in covered benefits, co‐pays, deductibles, coinsurance
• Applies to both insured and self‐insured plans
• Penalty for non‐compliance up to $1000 a day per incidence
PrePre‐‐Existing LimitationsExisting Limitations
October 2010• No pre‐ex limitations on dependents < age 192011• Cannot rescind group coverage except for case of fraud or misrepresentation– Advance notice required
2014• No pre‐ex limits for adults either• Applies to grandfathered plans too
Annual/Lifetime MaximumsAnnual/Lifetime Maximums
2011• No group health plan may impose a maximum lifetime
value dollar limit on “essential benefits”• Only “restricted” annual limits
– Plan years beginning:9/23/10 ‐ 9/22/11 $750,0009/23/11 – 9/22/12 $1.25 million9/23/13 – 1/1/14$2 million
2014• No annual limits
Coverage for Adult DependentsCoverage for Adult Dependents
2011• Must allow dependent coverage till age 26
– Even if married
– Even if they do not meet tax definition of dependent
• Penalty for non‐compliance $100 a day per incident
Other Plan Design ChangesOther Plan Design Changes
2011• Emergency Services
– Must be covered without pre‐authorization
– Must be covered in or out‐of‐network
• OB/GYN may be designated as PCP
• Preventive Care must be fully covered – No cost sharing
Consumer Driven Plan ChangesConsumer Driven Plan Changes
• January 2011– OTC meds no longer qualified expenses
• FSA, HRA, HSA
– Can get doctor’s order– OTC supplies still eligible– Switchover will vary by merchant (IIAS)– Penalty for non-qualified use of HSA funds
increased from 10% to 20%• January 2013
– FSA plan year contributions capped at $2500
Wellness IncentivesWellness Incentives
2011• $200 billion in grants available over 5 years for employers who
• Have fewer than 100 employers who work more than 25 hours a week and did not have a workplace wellness program as of 3/23/2010
• Employers may create up to 20% incentive for completion of wellness program
– Programs must meet minimum criteria established by HHS.
2014• Incentives of 30% (or up to 50% with HHS approval)
WW––2 Reporting2 Reporting
2011• Beginning in 2011 tax year, employers must report value of health benefits on employees W‐2.– Report aggregate cost of employer sponsored coverage including both employer and employee contributions (COBRA rate)
– Informational only. Not counted as income
Small Employer Tax CreditsSmall Employer Tax Credits
2010 – 2013• Up to 35% tax credit for employer contribution
– Small businesses with 25 or fewer EEs and avg. wages of $50,000 or less (full credit for 10 EE s and less)
– Who pay at least 50% of health insurance costs
2014
• Increase to 50% for businesses who buy through Exchange (for up to two years.)
• CBO estimates 12% of small business will qualify
Small Group RedefinedSmall Group Redefined
Beginning 2014
• Defined as 1 – 100– States can delay 51‐100 until January 2016
• Below 50 exempt from many provisions
Rate CompressionRate Compression
• 3:1 ratio
• Rating only on age, geographic location, coverage tier and tobacco use– 1.5 to 1
• Applies to small group market inside and outside of the Exchange
• 2014 – Risk adjustment inside and outside Exchange
Minimum Benefit PackageMinimum Benefit Package
• 90 day max waiting period
• Covers comprehensive set of services
• 60% of the actuarial value of covered benefits
• OOP limited to HSA levels $5,950 and $11,900
• Applies to individual and small group market– Except grandfathered plans
Carrier CCarrier A Carrier B Carrier D
The Exchange
Subsidy Payment & Reconciliation
(E) Plan Selection, Enrollment
( I) Premium Invoice
(P) Non-Subsidy Premium Payment
Reporting
(S) Determine Subsidy Eligibility/Amount
SE
IP
Individual ExchangePreferred Model
(Carriers could bill and collect.)
S EP
Carrier CCarrier A Carrier B Carrier D Carrier E
The Exchange
(E) Plan Selection, Enrollment
( I) Premium Invoice
(P) Group Premium Payment
Employer
Tax Credit Mechanism
E
P
I
PP
P
P P
E EE E E
Carrier Reconciliation
Precious Metal PlansPrecious Metal Plans
• All plans must meet HSA OOP limits• Bronze – covers 60% of benefit costs• Silver – 70%• Gold – 80%• Platinum – 90%• Catastrophic Plan for Young Invincibles
– Up to age 30 – Or exempted from mandates
• Carriers only have to offer silver and gold
Two Levels of SubsidyTwo Levels of Subsidy
Subsidize Premium through Tax Credits
• Contributions for silver plan limited to:133 – 150% of FPL: 3 to 4% of income
150 – 200% of FPL: 4 to 6.3% of income
200 – 250% of FPL: 6.3 to 8.05% of income
250 – 400% of FPL: 8.05 to 9.5% of income
300 – 400% of FPL: 9.5% of income
• Adjusted annually
Two Levels of SubsidyTwo Levels of Subsidy
Reduce Out‐of‐Pocket Maximums
• Out of pocket cost reductions– 100‐200% – one‐third of the HSA limits
– 200‐300% ‐ one‐half of the HSA limits
– 300‐400% ‐ two‐thirds of the HSA limits
• 2010 HSA OOP Limits– $5,950 individuals, $11,900 families
Employer Penalty Employer Penalty –– No PlanNo Plan
• Effective January 2014
• 50 or more EEs
• If you do not offer “minimum essential coverage” AND
• At least one full‐time employee receives subsidy through the Exchange– $2000 penalty per employee
– Excluding first 30 EEs
Real Cost of Dropping CoverageReal Cost of Dropping Coverage
Number of Employees 10,000
Less 30 exempted 9,970
Premium 8,863$
EE Contribution (25%) 2,216$
Employer Contribution (75%) 6,647$ Penalty (non-deductible)
($2000 per EE less 30 Ees) 1,994$
Loss of Deduction 798$
Net Cost 2,792$
Employee Compensation Increase (90% of employer contribution) 3,324$
Tax Gross Up (30%) 997$
Total Comp Expense 4,321$
Total Employer Cost 7,112$
Free Rider PenaltyFree Rider Penalty
Effective 2014• 50 or more EEs• Even if you offer coverage, subject to penalty if:
• Coverage is unaffordable because EE must contribute more than 9.5% of household income
• Or if plan covers less than 60% of covered health expenses• And one or more full‐time EEs receives a subsidy.• Lesser of:
• Penalty of $250 per month ($3,000) annually per subsidized EE– $2.000 multiplied by all full‐time employees, less 30 EEs
Free Choice VoucherFree Choice Voucher
• Applies to employees within 400% of the FPL– If their contribution cost is between 8% and 9.8 of their income
– And they want to buy coverage through the Exchange
• Employer must provide EE with a voucher equal to employer contribution to buy insurance through Exchange
• No penalty to employer who offers voucher
Bridge to Reform ChecklistBridge to Reform Checklist
• Develop wellness program. Apply for grant.
• Employee education– Online tools
• Couple high‐deductible with tax‐advantaged plans
• Consider automation tools, outsourcing
• Pay attention. Things will change.
Creative Design MixCreative Design Mix
$3050
HSA for Owners
$1850 HRA for Employees (Buy down deductible to $1200)
FSA for Employees(Covers 1st $1200)
$3050 deductible HSA-qualified insurance planPOP Plan
VariableCost
Fixed Cost
1040Deduction
Voluntary
WellnessIncentives
Education Leave Management
Dependent Care - $5000