WHY IT MATTERS THAT MORE PEOPLE SIGNED UP FOR ACA HEALTH COVERAGE IN 2018

From The ACA Times, let's take a look at ACA Health Coverage in 2018.


It was meant to have the opposite effect.

The Trump administration’s decision to undermine the Affordable Care Act (ACA) by shortening the annual open enrollment period to 45-days and cutting funding to promote open enrollment was predicted to reduce the number of people who might seek insurance coverage for 2018 on HealthCare.gov.

Instead, more than 600,000 people signed up for health insurance under the ACA in the first four days of enrollment. According to Reuters: “The Centers for Medicare & Medicaid Services, a division of the Department of Health and Human Services, said that during the period of Nov. 1 through Nov. 4, 601,462 people, including 137,322 new consumers, selected plans in the 39 states that use the federal website HealthCare.gov.”

Access to healthcare remains top of mind for Americans. For instance, exit polls in Virginia for state elections found healthcareto be the most pressing issue on the minds of voters who elected a Democratic governor in that state. And entrepreneurs and small businesses owners and employees are among those that benefit greatly from having access to healthcare insurance plans through the ACA.

For employers, all this, along with recent guidance from the IRS, points to the ACA continuing strong and the employer mandate being enforced. If you haven’t done so already, now is the time to assess your compliance with the ACA and what data you need to file ACA related forms with the IRS for the 2017 tax year.

 

Read the original article.

Source:
Sheen R. (20 November 2017). "WHY IT MATTERS THAT MORE PEOPLE SIGNED UP FOR ACA HEALTH COVERAGE IN 2018" [Web blog post]. Retrieved from address https://acatimes.com/why-it-matters-that-more-people-signed-up-for-aca-health-coverage-in-2018/


Tax Bill Shakes Up Health — From Medicare To The ACA To Medical Education

The tax bill that Republican lawmakers are finalizing would have wide-reaching effects on health issues. But the GOP still has negotiating ahead to get a bill that both the House and Senate will support. That hasn't stopped some party leaders from looking forward to additional plans to revamp programs such as Medicare and Medicaid.

The Associated Press: Q&A: Tax Bill Impacts On Health Law Coverage And Medicare The tax overhaul Republicans are pushing toward final votes in Congress could undermine the Affordable Care Act's health insurance markets and add to the financial squeeze on Medicare over time. Lawmakers will meet this week to resolve differences between the House- and Senate-passed bills in hopes of getting a finished product to President Donald Trump's desk around Christmas. Also in play are the tax deduction for people with high medical expenses, and a tax credit for drug companies that develop treatments for serious diseases affecting relatively few patients. (Alonso-Zaldivar, 12/5)

The Fiscal Times: 6 Critical Differences That Must Be Resolved in the Republican Tax Bills The Senate bill’s repeal of the Obamacare mandate saves about $318 billion over 10 years but threatens to destabilize the individual markets, resulting in higher premiums and millions fewer people with health insurance. While House Republicans aren’t likely to balk at including repeal in the final bill, it could still be a problem for Sen. Susan Collins (R-ME), a pivotal vote in the upper chamber, whose support for the final package could depend on Congress’s treatment of separate measures designed to stabilize the Obamacare markets. (Rainey, 12/4)

The Atlanta Journal-Constitution: Perdue Says Further Health Care Changes ‘Absolutely’ Needed As House and Senate lawmakers open another phase of negotiations over a $1.5 trillion federal tax overhaul, some Republicans are emboldened about pursuing new cuts to the system of health care entitlements. U.S. Sen. David Perdue said Monday that lawmakers should “absolutely” seek changes to the Medicaid and Medicare programs to help maximize the impact of the tax cuts. He echoed other Republican officials who have suggested a push for more spending cuts should be in the works. (Bluestein, 12/4)

 

Read the original brief.

Source:
Kaiser Health News (5 December 2017). "Tax Bill Shakes Up Health — From Medicare To The ACA To Medical Education" [Web blog post]. Retrieved from address https://khn.org/morning-breakout/tax-bill-shakes-up-health-from-medicare-to-the-aca-to-medical-education/


Trump picks former Lilly drug executive as health secretary

We're sure you've seen it trending. Here is the latest on President Trump's new hire, Alex Azar of Eli Lilly & Co - the U.S.A.'s new head of the Department of Health and Human Services.


(Bloomberg) – President Donald Trump named former Eli Lilly & Co. executive Alex Azar to lead the Department of Health and Human Services after agency’s past chief resigned amid blowback over his taxpayer-funded private jet travel.

“Happy to announce, I am nominating Alex Azar to be the next HHS Secretary. He will be a star for better healthcare and lower drug prices!” Trump tweeted Monday.

If confirmed, Azar will take over the administration’s management of the Affordable Care Act. Trump and Congressional Republicans have called to repeal the health law, and the administration has taken steps to destabilize it, such as cutting funding for some programs and refusing to pay subsidies to health insurers. He’ll also be a key figure on drug costs.

Bloomberg/file photo

Trump has been highly critical of the drug industry, saying that pharmaceutical companies are “getting away with murder” and threatening to use the federal government’s buying power to bring down prices.

Drug Costs

However he’s taken no concrete action yet to do much on prices, and the former drug executive’s appointment may continue the trend of strong talk but little action, said Spencer Perlman, director of health-care research at Veda Partners, a policy analysis firm.

“It is very unlikely the administration will take aggressive regulatory actions to control prescription drug prices,” Perlman said in a note to clients Monday. “The administration’s tepid response to drug pricing has not matched the president’s heated rhetoric.”

Dan Mendelson, president of Avalere Health, a consulting firm, also didn’t think Azar represented a change in direction on pharmaceutical policy. “His appointment will not change the president’s rhetoric,” Mendelson said in a phone interview.

Before his time at Lilly, Azar served as deputy secretary at HHS under President George W. Bush. One former Obama administration official said that experience could help him at the agency.

“While we certainly differ in a number of important policy areas, I have reason to hope he would make a good HHS secretary,” said Andy Slavitt, who ran the Centers for Medicare and Medicaid Services under the last administration and who has been a frequent critic of efforts to derail Obamacare. Slavitt said he hoped Azar would “avoid repeating this mistakes of his predecessor over-politicizing Americans’ access to health care.”

Running Obamacare

Azar, who ran Indianapolis-based Lilly’s U.S. operations until earlier this year, has been an advocate for more state flexibility under Obamacare. That matches up with what Republicans have pushed for, such as in a seemingly stalled bipartisan bill to fund insurer subsidies that help lower-income people with health costs.

As secretary, Azar would have broad authority over the program.

“I’m not one to say many good things about Obamacare, but one of the nice things in it is it does give a tremendous amount authority to the secretary,” Azar said during an interview with Bloomberg TV in June. “There are still changes that can be made to make it work a little better than it has been.”

There are signs that the law is gaining popular support despite the repeal efforts. In recent state elections in Virginia, Democrats won a competitive governors race that saw health care emerge as a top issue. In Maine, residents voted to expand Medicaid under the Affordable Care Act. Early enrollment in Obamacare plans earlier this month was also up considerably compared to last year.

Trump’s first HHS secretary, Tom Price, resigned in September after his extensive use of private and military jets at taxpayer expense was revealed. Azar must be approved by the Senate.

Senate Confirmation

Senator Orrin Hatch, who heads the Senate Finance Committee that will review Azar’s nomination, called on Trump’s pick to help “right the wrongs of this deeply flawed law.”

“For too long, hardworking, middle-class families have been forced to bear the brunt of Obamacare’s failures in the form of higher premiums and fewer choices,” Hatch said in a statement.

Ron Wyden, the senior Democrat on the panel, said he would closely scrutinize Azar’s record.

“At every turn, the president has broken his promises to American families to lower health care costs, expand access, and bring down the high price of prescription drugs,” Wyden said in a statement.

Azar left Lilly in January, several months after another senior executive was named to succeed then-CEO John Lechleiter. A lawyer by training, Azar previously clerked for Antonin Scalia on the Supreme Court.

You can read the original article here.

Source:

Employee Benefit Advisors (13 November 2017). "Trump picks former Lilly drug executive as health secretary" [Web blog post]. Retrieved from address https://www.employeebenefitadviser.com/articles/trump-picks-former-lilly-drug-executive-as-health-secretary?tag=00000151-16d0-def7-a1db-97f024b50000

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HRL - Pills - Glass

Medicare Advantage: How Robust Are Plans’ Physician Networks?


You can read the original article here.

Source:

Jacobson G. (5 October 2017). "Medicare Advantage: How Robust Are Plans’ Physician Networks?" [Web Blog Post]. Retrieved from address https://www.kff.org/medicare/report/medicare-advantage-how-robust-are-plans-physician-networks/

One of the biggest trade-offs between Medicare Advantage and traditional Medicare is that Medicare Advantage plans have a more limited network of doctors and other providers. The size and breadth of provider networks can be an important factor for beneficiaries when choosing between traditional Medicare and Medicare Advantage, and among Medicare Advantage plans. As of 2017, 19 million of the 58 million people on Medicare (33%) are enrolled in a Medicare Advantage plan, yet little is known about their provider networks.

19 million people on Medicare are in a #MedicareAdvantage plan, yet little is known about their provider networks. 

This report is the first known study to examine the size and composition of Medicare Advantage plans’ physician networks. This analysis draws upon data from 391 plans, offered by 55 insurers in 20 counties, and accounted for 14% of all Medicare Advantage enrollees nationwide in 2015. Key findings include:

Figure ES-1: One in three Medicare Advantage enrollees were in plans with narrow physician networks

  • More than three in ten (35%) Medicare Advantage enrollees were in narrow-network plans while about two in ten (22%) were in broad-network plans. To some degree, the relative narrowness of plan networks masks the total number of physicians that enrollees could access, particularly in larger counties.
  • Medicare Advantage networks included less than half (46%) of all physicians in a county, on average.
  • Network size varied greatly among Medicare Advantage plans offered in a given county. For example, while enrollees in Erie County, NY had access to 60% of physicians in their county, on average, 16% of the plans in Erie had less than 10% of the physicians in the county while 36% of the plans had more than 80% of the physicians in the county.
  • Access to psychiatrists was typically more restricted than for any other specialty. Medicare Advantage plans had 23% of the psychiatrists in a county, on average; 36% of plans included less than 10% of psychiatrists in their county. Some plans provided relatively little choice for other specialties as well; 20% of plans included less than 5 cardiothoracic surgeons, 18% of plans included less than 5 neurosurgeons, 16% of plans included less than 5 plastic surgeons, and 16% of plans included less than 5 radiation oncologists.
  • Broad-network plans tended to have higher average premiums than narrow-network plans, and this was true for both HMOs ($54 versus $4 per month) and PPOs ($100 versus $28 per month).

Insurers may create narrow networks for a variety of reasons, such as to have greater control over the costs and quality of care provided to enrollees in the plan. The size and composition of Medicare Advantage provider networks is likely to be particularly important to enrollees when they have an unforeseen medical event or serious illness. However, accessing the information may not be easy for users, and comparing networks could be especially challenging. Beneficiaries could unwittingly face significant costs if they accidentally go out-of-network. Differences across plans, including provider networks, pose challenges for Medicare beneficiaries in choosing among plans and in seeking care, and raise questions for policymakers about the potential for wide variations in the healthcare experience of Medicare Advantage enrollees across the country.

You can read the original article here.

Source:

Jacobson G. (5 October 2017). "Medicare Advantage: How Robust Are Plans’ Physician Networks?" [Web Blog Post]. Retrieved from address https://www.kff.org/medicare/report/medicare-advantage-how-robust-are-plans-physician-networks/


HRL - White - House

President Trump Ends ACA Cost Sharing Reductions

On the evening of October 12, 2017, President Trump announced that cost-sharing reductions for low-income Americans in relation to the Patient Protection and Affordable Care Act (ACA) would be stopped. The Department of Health and Human Services (HHS) has confirmed that payments will be stopped immediately. It is anticipated at least some state attorney generals will file lawsuits to block the ending of the subsidy payments, with California Attorney General Xavier Becerra stating he is prepared to file a lawsuit to protect the subsidies.

Background

Individuals with household modified adjusted gross incomes (AGI) in excess of 100 percent but not exceeding 400 percent of the federal poverty level (FPL) may be eligible for cost-sharing reductions for coverage purchased through health insurance exchanges if they meet a variety of criteria. Cost-sharing reductions are limited to coverage months for which the individual is allowed a premium tax credit. Eligibility for cost-sharing reductions is based on the tax year for which advanced eligibility determinations are made by HHS, rather than the tax year for which premium credits are allowed. In 2015, cost-sharing subsides reduced out-of-pocket (OOP) limits:

· Less than 100 percent but not exceeding 200 percent of FPL: OOP limits reduced by two-thirds
· Greater than 200 percent but not exceeding 300 percent of FPL: OOP limits reduced by one-half
· Greater than 300 percent but not exceeding 400 percent of FPL: OOP limits reduced by one-third

After 2015, the base percentages were shifted based on a percentage of average per capita health insurance premium increases. The cost-sharing reduction is paid directly to the insurer, and is automatically applied when eligible individuals enroll in a silver plan on the Marketplace or Exchange.

The cost-sharing reduction is not the same as the "advance premium tax credit" which is also available to individuals with household modified AGIs of at least 100 percent and not exceeding 400 percent of the FPL.

Impact on Employers

There is no direct impact to employers at this time. However, employers with fully insured health plans might see group health plan rate increases in future years as insurance companies work to make up for the loss of revenue.

 


High-Performing ACA Navigators Mystified By Deep Cuts Less Than Year After Being Touted As ‘Superstars’

What's the latest on the effects of President Trump's executive order on health care? We pulled this article from Kaiser Health News, which includes multiple sources for information. Check them out and stay up-to-date with us!


You can read the original article here.

Source:

Kaiser Family Foundation (10 October 2017). "High-Performing ACA Navigators Mystified By Deep Cuts Less Than Year After Being Touted As ‘Superstars’" [Web Blog Post]. Retrieved from address https://khn.org/morning-breakout/high-performing-aca-navigators-mystified-by-deep-cuts-less-than-year-after-being-touted-as-superstars/

 

“We have yet to receive any explanation of the cut. We have met or exceeded every one of our performance metrics. There was never any feedback that gave us any indication that we were not going to receive the same amount,” says Lisa Hamler-Fugitt, the executive director of the Ohio Association of Foodbanks. The Trump administration slashed funding for theses navigators by more than 40 percent nationally, with some places seeing cuts of nearly 90 percent.

The New York Times: Trump’s Cuts To Health Law Enrollment Efforts Are Hitting Hard
Michigan Consumers for Health Care, a nonprofit group, has enrolled thousands of people in health insurance under the Affordable Care Act and was honored last year as one of the nation’s top performers — a “super navigator” that would serve as a mentor to enrollment counselors in other states. So the group was stunned to learn from the Trump administration that its funds for assisting consumers ahead of the open enrollment period that begins Nov. 1 would be cut by 89 percent, to $129,900, from $1.2 million. (Pear, 10/9)
Meanwhile, in other health law news —
The Hill: Trump Could Make Waves With Health Care Order 
President Trump's planned executive order on ObamaCare is worrying supporters of the law and insurers, who fear it could undermine the stability of ObamaCare. Trump’s order, expected as soon as this week, would allow small businesses or other groups of people to band together to buy health insurance. Some fear that these Association Health Plans (AHPs) would not be subject to the same rules as ObamaCare plans, including those that protect people with pre-existing conditions. (Sullivan, 10/10)
Politico: Republicans Privately Admit Defeat On Obamacare Repeal
For the first time, rank-and-file Republicans are acknowledging Obamacare may never be repealed. After multiple failures to repeal the law, the White House and many GOP lawmakers are publicly promising to try again in early 2018. But privately, both House and Senate Republicans acknowledge they may never be able to deliver on their seven-year vow to scrap the law. (Haberkorn, 10/9)
You can read the original article here.Source:Kaiser Family Foundation (10 October 2017). "High-Performing ACA Navigators Mystified By Deep Cuts Less Than Year After Being Touted As ‘Superstars’" [Web Blog Post]. Retrieved from address https://khn.org/morning-breakout/high-performing-aca-navigators-mystified-by-deep-cuts-less-than-year-after-being-touted-as-superstars/


HRL - White - House

4 Main Impacts of Yesterday's Executive Order

Yesterday, President Trump used his pen to set his sights on healthcare having completed the signing of an executive order after Congress failed to repeal ObamaCare.

Here’s a quick dig into some of what this order means and who might be impacted from yesterday's signing.

A Focus On Small Businesses

The executive order eases rules on small businesses banding together to buy health insurance, through what are known as association health plans, and lifts limits on short-term health insurance plans, according to an administration source. This includes directing the Department of Labor to "modernize" rules to allow small employers to create association health plans, the source said. Small businesses will be able to band together if they are within the same state, in the same "line of business," or are in the same trade association.

Skinny Plans

The executive order expands the availability of short-term insurance policies, which offer limited benefits meant as a bridge for people between jobs or young adults no longer eligible for their parents’ health plans. This extends the limited three-month rule under the Obama administration to now nearly a year.

Pretax Dollars

This executive order also targets widening employers’ ability to use pretax dollars in “health reimbursement arrangements”, such as HSAs and HRAs, to help workers pay for any medical expenses, not just for health policies that meet ACA rules. This is a complete reversal of the original provisions of the Obama policy.

Research and Get Creative

The executive order additionally seeks to lead a federal study on ways to limit consolidation within the insurance and hospital industries, looking for new and creative ways to increase competition and choice in health care to improve quality and lower cost.


ERISA's "Church Plan" Exception

Great article from our partner, United Benefit Advisors (UBA) by Danielle Capilla.

The Employee Retirement Income Security Act (ERISA) was signed in 1974. The U.S. Department of Labor (DOL) is the agency responsible for administering and enforcing this law. For many years, most of ERISA's requirements applied to pension plans. However, in recent years that has changed, and group plans (called "welfare benefit plans" by ERISA and the DOL) now must meet a number of requirements. Government and church plans do not need to comply with ERISA.

However, some employers are unsure if they meet ERISA's "church plan" exception. Entities associated with churches such as hospitals, schools, nursing homes, and charities are often unclear about whether they meet the exception. Under ERISA, a church plan is "any employee benefit plan established and maintained by a church or by a convention or association of churches that is exempt from tax under IRS Code Section 501 with respect to which no election has been made under IRS Code Section 410(d). The plan must be established and maintained primarily for benefit of the employees of a church or convention or association of churches. Substantially all the covered individuals under the plan must be employees of the church or the convention or association of churches.

Although this might seem straightforward at first glance, determining whether a church or convention or association of churches exists is dependent on the facts and circumstances of an organization. Organizations may request a DOL opinion letter, or an IRS private letter ruling (although the DOL reserves the right to review IRS determinations via private letter) to determine if they meet the definition. To add another layer of uncertainty, courts are not bound by either DOL or IRS determinations.

See the original article Here.

Source:

Capilla D. (2017 August 3). ERISA's "church plan" exception [Web blog post]. Retrieved from address http://blog.ubabenefits.com/erisas-church-plan-exception-1


New House Healthcare Proposal a Mixed Bag for Employers

The House of Representatives has just introduced their new bipartiasn plan for healthcare reform. Find out how this new healthcare legislation will impact your employers' healthcare in this great article by Victoria Finkle from Employee Benefit News.

A new bipartisan healthcare plan in the House contains potential positives and negatives alike for employers.

The plan could provide much-sought relief to small and medium-sized businesses with respect to the employer mandate, but it could also institutionalize the mandate for larger firms and does little to reduce employer-reporting headaches. Critics say it also fails to endorse other employer-friendly reforms to the Affordable Care Act.

The Problem Solvers Caucus, a group of more than 40 Republicans and Democrats led by Reps. Tom Reed, R-N.Y., and Josh Gottheimer, D-N.J., unveiled their new plan last week to stabilize the individual markets, following the collapse of Senate talks that were focused on efforts to repeal and replace the Affordable Care Act last month. The proposal would be separate from an earlier bill that passed the House to overhaul large swaths of the ACA. Congress is now on recess until after Labor Day, but talks around efforts to shore up the individual markets are likely to resume when lawmakers return to Washington this fall.

PaulThe House lawmakers introduced a broad set of bipartisan principles that they hope will guide future legislation, including several key tweaks to the employer mandate. This plan includes raising the threshold for when the mandate kicks in from firms with 50 or more employees to those with at least 500 workers. It also would up the definition of full-time work from those putting in 30 hours to those working 40 hours per week. Among changes focused on the individual markets, the proposal would bring cost-sharing reduction payments under the congressional appropriations process and ensure they have mandatory funding as well as establish a stability fund that states could tap to reduce premiums and other costs for some patients with expensive health needs.

Legislative talks focused on maintaining the Obamacare markets remain in early stages and it’s unclear whether the provisions targeting the employer mandate will gain long-term traction, though lawmakers in support of the plan said that their proposed measure would help unburden smaller companies.

“The current employer mandate places a regulatory burden on smaller employers and acts as a disincentive for many small businesses to grow past 50 employees,” the Problem Solvers Caucus said in their July 31 release.

Observers note that raising the mandate’s threshold would likely have few dramatic effects on coverage rates. But critics argued that while the plan would eliminate coverage requirements for mid-size employers — a boon for smaller companies — it could ultimately make it more difficult to restructure or remove the mandate altogether.

“It would provide relief to some people — however, it will enshrine the employer mandate forever,” says James Gelfand, senior vice president of health policy at the ERISA Industry Committee. “You are exempting the most sympathetic characters and ensuring that large businesses will forever be subject to the mandate and its obscene reporting.”

The real-world impact of the change would likely be limited when it comes to coverage rates, as mid-sized and larger employers tend to use health benefits to help attract and retain their workforce. Nearly all firms with 50 or more full-time employees — about 96% — offered at least one plan that would meet the ACA’s minimum value and affordability requirements, according to the Kaiser Family Foundation/Health Research & Education Trust employer health benefits survey for 2016. Participation was even higher — 99% — among firms with at least 200 workers.

“At the 500 bar, realistically, virtually every employer is offering coverage to at least some employees,” says Matthew Rae, a senior policy analyst with Kaiser Family Foundation.

Gelfand notes that under the proposed measure, big businesses would still have to comply with time-consuming and costly reporting requirements under the ACA and would continue to face restrictions in plan design, because of requirements in place that, for example, mandate plans have an actuarial value of at least 60%.

“Prior to the ACA, big business already offered benefits — and they were good benefits that people liked and that were designed to keep people healthy and to make them productive workers,” he says. “[The ACA] forces us to waste a boatload of time and money proving that we offer the benefits that we offer and it constrains our ability to be flexible in designing those benefits.”

Susan Combs, founder of insurance brokerage Combs & Co., says that changing the definition of full-time employment from 30 to 40 hours per week could have a bigger impact than raising the mandate threshold, because it would free up resources for employers who had laid off workers or cut back their hours when they began having to cover benefits for people working 30 or more hours.

“Some employers had to lay off employees or had they to cut back on different things, because they had to now cover benefits for people that were in essence really part-time people, not full-time people,” she says. “If you shifted from 30 to 40 hours, that might give employers additional remedies so they can expand their companies and employ more people eventually.”

Two percent of firms with 50-plus full-time workers surveyed by Kaiser in 2016 said that they changed or planned to change the job classifications of some employees from full-time to part-time so that the workers would not be eligible for health benefits under the mandate. Another 4% said that they reduced the number of full-time employees they intended to hire because of the cost of providing health benefits.

Gelfand calls the provision to raise the definition from 30 to 40 hours per week “an improvement,” though he said a better solution would be to remove the employer mandate entirely.

He added that he would like to see any market stabilization plan include more items employers had backed as part of the earlier repeal and replace debate. While the House plan would remove a tax on medical devices, it does not address the Cadillac tax on high-cost plans, one of the highest priority items that employer groups have been working to delay or repeal. It also doesn’t include language expanding the use of tax-advantaged health savings accounts detailed in earlier House and Senate proposals.

“There’s not likely to be another healthcare vehicle that’s focused on ACA reform, so if you have a reform vehicle that goes through and it doesn’t do anything to give us tax relief and it doesn’t do anything to improve consumer-driven health options, like HSAs, and it doesn’t do anything to improve healthcare costs — wow, what a missed opportunity,” he says.

See the original article Here.

Source:

Finkle V. (2017 August 10). New house healthcare proposal a mixed bag for employers [Web blog post]. Retrieved from address https://www.benefitnews.com/news/new-house-healthcare-proposal-a-mixed-bag-for-employers


Determining COBRA Premiums for Fully Insured and Self-Funded Health Plans

Here is a great article from our partner, United Benefit Advisors (UBA) on what you need to know about COBRA when dealing with fully insured and self-funded health plans by Danielle Capilla.

The Consolidated Omnibus Budget Reconciliation Act of 1985 (COBRA) allows qualified beneficiaries who lose health benefits due to a qualifying event to continue group health benefits. While some group health plans may provide COBRA continuation coverage at a reduced rate or at no cost, most qualified beneficiaries must pay the full COBRA premium. The COBRA election notice should include information about COBRA premiums.

For fully insured health plans, the premium is the cost to maintain the plan for similarly situated employees. For self-insured plans, the premium is the cost to maintain the plan for similarly situated employees as determined by an actuary or the past cost from the preceding determination period. The applicable premium calculation for both fully- and self-insured plans includes the cost of providing coverage to both active employees and COBRA qualified beneficiaries. All COBRA premiums must be calculated in good faith compliance with a reasonable interpretation of COBRA requirements.

Generally, COBRA payments are made on an after-tax basis. Qualified beneficiaries have 45 days after the election date to make an initial premium payment. The plan may terminate the qualified beneficiary's COBRA rights if no initial premium payment is made before the end of the 45-day period. In addition, plans must allow monthly premium payments and cannot require payment on a quarterly basis. As established under COBRA, premiums are due on the first day of each month with a minimum 30-day grace period. A plan may terminate COBRA coverage for nonpayment or insufficient payment of premiums after the grace period.

If a qualified beneficiary makes an insignificant underpayment, then the premium payment will still satisfy the payment obligation. An underpayment is deemed insignificant if the shortfall is no greater than the lesser of $50 or 10 percent of the required amount. However, if the plan notifies the qualified beneficiary of the shortfall and grants a reasonable amount of time to correct the underpayment (usually 30 days after the notice is provided), then the qualified beneficiary is required to make the payment; otherwise, COBRA coverage may be canceled.

Fully Insured Health Plans

Generally, the applicable COBRA premium amount for fully insured plans is the insurance premium charged by the insurer. The applicable premium is based on the total cost of coverage, which includes both the employer and employee portions. The premium amount is based on the cost of coverage for similarly situated individuals who have not incurred a qualifying event.

A group health plan may charge at most 102 percent of the premium during the standard COBRA coverage period for similarly situated plan participants (100 percent of the total cost of coverage plus an additional 2 percent for administrative costs). However, the plan may increase the premium for a disabled qualified beneficiary and charge 150 percent of the applicable premium during the 11-month disability extension period (months 19 through 29). In addition, COBRA regulations permit a plan to charge a 150 percent premium to nondisabled qualified beneficiaries as long as the disabled qualified beneficiary is covered under the plan. If the disabled qualified beneficiary is no longer covered under the plan, then the remaining qualified beneficiaries may continue coverage up to 29 months at 102 percent of the cost of the plan.

If an employer maintains more than one plan, then a separate applicable premium is calculated for each plan. Also, the applicable premium for a single plan may vary due to factors such as the coverage level, the benefit package, and the region in which covered employee resides. For instance, single employees may pay a different applicable premium than employees who include their spouse on the plan. Thus, the plan may charge different premiums based on the varying coverage levels.

The most common tier structures include employee-only, employee-plus-spouse, employee-plus-children, and employee-plus-family. According to Internal Revenue Ruling 96-8, a fully insured plan that pays different premiums for individual versus family coverage must use those same premium tiers for COBRA continuation coverage. Thus, COBRA premiums are divided into multi-rate and single-rate tier structures.

See the original article Here.

Source:

Capilla D. (2017 August 1). Determining COBRA premiums for fully insured and self-funded health plans [Web blog post]. Retrieved from address http://blog.ubabenefits.com/determining-cobra-premiums-for-fully-insured-and-self-funded-health-plans-1