Health plan sponsors are required to supply, at least annually, a special notice to their enrollees who are also covered by Medicare. The special notice indicates whether the plan's prescription drug coverage is "creditable" - that is, at least as good as Medicare Part D, on an actuarial basis. The "Medicare Part D notice" helps enrollees who are covered by Medicare make informed and timely decisions about whether and when to enroll in Medicare Part D, and avoid a Medicare late enrollment penalty. Although a plan sponsor's obligation to supply a notice extends only to enrollees who are covered by Medicare, plans sometimes do not know which enrollees actually have Medicare coverage. As a result, plans often simply distribute the Part D notice to all participants. As a part of my firm's services, we furnish our clients with the actuarial attestation of Medicare Part D creditable coverage along with the sample notice. What should be important to plan sponsors is an impending distribution notice due this year as early as October 15th. If you are interested in receiving our firm's analysis of the rules impacting this notice distribution deadline, a complimentary copy is being made available to members of our BenefitU group in LinkedIn.
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Dan Pink @ TED - Presentation on the Science of Motivation
Listen in and apply these principles to our corporate-wellness initiatives. We could not agree more that intrinsic over extrinsic motivators provide longer-term results. We welcome your comments below and invite you to read Dan Pink's Drive to compare with Thaler and Sunstein's Nudge.
IRS Affordability Standard - New Health Reform Guidance
What an interesting week in the land of employee benefits. A federal appeals court struck down the constitutionality of the healthcare reform's individual mandate virtually guaranteeing that the Supreme Court will weigh in on the disputes now surfacing between the 11th Circuit and others. Remember hanging-chad anyone? Once again our politics got in the way so our national policies will be determined by the "heavies" in the highest court in the land. Now onto two federal healthcare requirements that had our employer plan sponsor clients wondering if sanity would prevail in Washington. As a reminder, the statute requires employers with 50 full-time employees or more to offer health insurance to employees and dependents in 2014. The law requires the coverage to be both "affordable" and "qualifying" in order to avoid penalties.
The answer to both is good news for employer plan sponsors. The IRS used broad discretionary powers to define affordability if the employee is not required to pay more than 9.5% of an employee's current W-2 wages. The more muddier definition of household income through AGI verfication now gives way to something the employer has in their purview as a data point. So an employee earning $40k a year would be prohibited from single contributions in excess of $316.67 a month.
Additionally, employers caught a reprieve by IRS guidance on the new "qualifying" definition, which varies from the standard imposed in the state exchanges. The 60% standard has now been interpreted to mean the percentage of charges covered by the plan. So for every dollar of eligible health expenses incurred under the plan, Uncle Sam wants to see the plan picking up sixty cents of the tab. Finally, employers were given another bonus by exempting plan sponsors from the "essential benefits" definition being crafted for plans under the state exchanges.
For more information and a nice write up by our Health Reform Advisor Practice, please go here.
Health Insurance - When You've Tried Everything Else
Are you no longer eligible for benefits under a group health plan? Have your COBRA benefits been exhausted? Have you been denied coverage due to a preexisting condition? Finding individual health coverage can be discouraging, especially when you have a health condition. But this post is about throwing you a lifeline. Texas is among many states which offer the Pre-Existing Condition Insurance Plan (PCIP), a federally funded insurance plan which offers insurance to people with ongoing or chronic medical conditions, at prices that are now more affordable.
These plans offer a broad range of coverage, including primary and specialty care, hospital care and prescription drug coverage. Maximum annual out of pocket cost for covered services is $5950 for network services and $7000 for out-of-network care. With a little help from the federal government, annual premiums are on the decline. Kathleen Sebelius, Secretary of Health and Human Services, announced recently that premiums have been reduced 10-20% in Texas. Similar cuts were made in Georgia, Indiana, Louisiana, Mississippi, Nebraska, South Carolina, Tennessee, West Virginia and the District of Columbia. Even greater cuts, some up to 40%, were made in Alabama, Arizona, Delaware, Florida, Kentucky, Minnesota, Nevada and Virginia. And, most remaining states have opted to take this federal money and design their own similar programs. So, no matter where you reside, you should be able to find a plan to fit your needs without denial from a reputable insurance company.
You may be eligible for the PCIP if you:
- Have been without health coverage for at least six months
- Have a preexisting condition or have been denied health coverage because of a health condition
- Are a U.S. citizen or reside in the U.S. legally
To apply for coverage in Texas, you must provide proof of residency and proof that you have been denied coverage. Proof of coverage denial may be a doctor's letter dated within the last 12 months, a denial letter from a Texas-licensed insurance company, a letter of ineligibility from a Texas-liscensed agent or insurance company, or an offer of coverage that excludes one's preexisting condition.
Getting the protection you need is simple. Apply online at www.pcip.gov, or visit the website to print out the application and submit it by mail or fax.
For questions about this and other state and federally supported insurance plans, you may contact the Texas Consumer Health Assistance Program (CHAP); they have the resources to help you when you need it the most. Contact 1-855-TEX-CHAP, Monday through Friday, from 8 am to 5 pm CST, or go online at www.TexasHealthOptions.com.
If this post helped you or a former employee looking for assistance ... please let us know. It is important for us to hear feedback when information we publish helps others.
Sources: Dallas Morning News, TDI Newsletter
A Plan "Hatched" To Bolster Health Savings Accounts
This year health care costs are expected to rise by more than double the rate of inflation. HSAs and FSAs provide individuals with opportunities to put away tax free savings for everyday medical expenses. When Congress first made HSAs available, these plans only covered 454,000 lives. Today, more than 10 million people are covered under a health plan that is eligible for an HSA. U.S. Senator Orrin Hatch (R-Utah), Ranking Member of the Senate Finance Committee, today unveiled the Family and Retirement Health Investment Act of 2011, bicameral legislation to strengthen and expand Health Savings Accounts (HSAs) and Flexible Spending Arrangements (FSAs) for American workers and retirees. Companion legislation was introduced in the U.S. House of Representatives by U.S. Rep. Erik Paulsen (R-Minn.).The Family and Retirement Health Investment Act of 2011 will streamline these health care products and simplify them for American families, seniors, and entrepreneurs.
Specifically, the legislation will:
- allow a husband and wife to make catch-up contributions to the same HSA; - remove the onerous new restrictions on the use of HSA and FSA dollars for the purchase of over-the-counter drugs; - allow individuals to roll-over up to $500 from their FSA accounts; - clarify the use of prescription drugs as preventive care that will not be subject to an HSA-eligible plan deductible; - reauthorize the use of Medicaid health opportunity accounts; - promote wellness by expanding the definition of qualified medical expenses to encourage more exercise and better diet; - allow seniors enrolled in Medicare Part A to continue contributing to their HSAs; and - allow for the purchase of low-premium health insurance and long-term care insurance with HSA dollars.
We are witnessing an adoption rate of HSAs that is tracking with similar "hockey stick" patterns experienced by 401(k)s when first introduced. While this is not a cure-all for the fee for service sick care delivery system, we applaud efforts to better align trade offs that improve tax efficiency in health plan design.