UBA Survey: Weary Families Get a Break While Singles See Out-of-Pocket Cost Increases

Below, our partner, UBA Benefits, has provided some insight from their 2017 Health Plan Survey. If you are an employer seeking customized results from the survey, we can help you. Please visit our survey page here.


While the rate impact of the regulatory environment plays out, one thing is clear from the 2017 UBA Health Plan Survey: employers continue to shift a greater share of expenses to employees through out-of-pocket cost increases. While this is just one of 7 mega trends uncovered in the survey, it is particularly interesting this year because singles were hit more heavily than families as compared to years past.

While average annual total costs per employee increased from $9,727 to $9,934, employees’ share of total costs rose 5%, from $3,378 to $3,550, while employers’ share rose less than 1%, from $6,350 to $6,401. The good news for employees is that, for a second year in a row, median in-network deductibles for singles and families held steady at $2,000 and $4,000, respectively. Similarly, some out-of-network deductibles remained unchanged, with families’ median out-of-network deductible remaining at $8,000 in 2017. Conversely, singles, who had been holding steady in 2014 and 2015 at a $3,000 median out-of-network deductible, saw a 13.3% increase to $3,400 in 2016, and another jump in 2017 to $4,000. Since deductible increases help employers avoid premium increases, we will likely see this trend continue, especially as insurance carriers are required to meet the ACA metal levels.

Both singles and families also are seeing continued increases in median in-network out-of-pocket maximums, up to $5,000 and $10,000, respectively. Families bore the brunt of the increase in median out-of-network out-of-pocket maximums between 2014 and 2016, going from $16,000 in 2014 to $18,000 in 2015, to $20,000 in 2016, but then holding steady at $20,000 in 2017. The maximum for singles, which had remained steady at $9,000 in 2015 and 2016, increased in 2017 to $10,000.

Interestingly, out-of-network expenses are not subject to ACA limitations, so it was theorized that they’d likely continue to skyrocket with more plans eliminating out-of-pocket maximums for non-network services. Perhaps to offset that, more employers adopted plans with no deductible for out-of-network services, while employees saw a massive decrease in the number of employers offering no deductible for in-network services. Looking at deductibles and out-of-pocket costs just among the ever-dominant PPO plans, in-network and out-of-network deductibles for families and singles are generally below average. However, the median in-network single deductible for PPO plans has held steady at $1,500 in 2016 and 2017, along with the family deductible at $3,000. The increases were seen in the out-of-pocket maximums, which rose in 2017 to $4,500 for single (up from $4,000 in 2016), and to $10,000 for family coverage (up $1,000 from $9,000 in 2016).

Read the original article here.

Source:
Olson B. (21 November 2017). "UBA Survey: Weary Families Get a Break While Singles See Out-of-Pocket Cost Increases" [Web blog post]. Retrieved from address http://blog.ubabenefits.com/uba-survey-weary-families-get-a-break-while-singles-see-out-of-pocket-cost-increases


Two Months After Hurricane Maria, A Growing Majority Of Americans Say Puerto Ricans are Not Yet Getting the Help They Need

Two months after Hurricane Maria struck Puerto Rico, a growing majority of Americans say that Puerto Ricans affected by the devastating storm are not yet getting the help they need, the November Kaiser Family Foundation Tracking Poll finds.

This month, 70 percent of the public say that people in Puerto Rico are not yet getting the help they need, up from 62 percent in October 2017. These perceptions vary by party, and half of Republicans (52%) now say Puerto Ricans aren’t yet getting needed help, up significantly from October (38%).

When asked whether the federal government is doing enough to restore electricity and access to food and water in Puerto Rico or not, a majority of the public (59%) says the federal government is not doing enough, up from 52 percent in October. Most Democrats (86%) and independents (59%) say the federal government is not doing enough, but most Republicans (63%) say it is doing enough.

In contrast, Americans see the recovery efforts in Texas following Hurricane Harvey in late August progressing more positively. Most (60%) of the public says Texans are getting the help they need, twice the share (31%) who say Texans aren’t yet getting needed help.

puertoricopoll.png

The poll finds similar shares of Americans they are closely following news about recovery efforts in Puerto Rico (63%) and in Texas (58%).  Democrats are somewhat more likely to report closely following news about the Puerto Rico recovery (75%) than are independents (61%) and Republicans (54%). In contrast, there are no partisan differences for those following news about Texas.

Designed and analyzed by public opinion researchers at the Kaiser Family Foundation, the poll was conducted from November 8 – 13, 2017 among a nationally representative random digit dial telephone sample of 1,201 adults. Interviews were conducted in English and Spanish by landline (415) and cell phone (786). The margin of sampling error is plus or minus 3 percentage points for the full sample. For results based on subgroups, the margin of sampling error may be higher.

 

You can read the original article here.

Source:

Kaiser Family Foundation (20 November 2017). "Two Months After Hurricane Maria, A Growing Majority Of Americans Say Puerto Ricans are Not Yet Getting the Help They Need" [Web blog post]. Retrieved from address https://www.kff.org/other/press-release/poll-two-months-after-hurricane-maria-a-growing-majority-of-americans-say-puerto-ricans-are-not-ye-getting-the-help-they-need/

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ANALYSIS: More than Half of Uninsured People Eligible for Marketplace Insurance Could Pay Less for Health Plan than Individual Mandate Penalty

Things are not looking up for the uninsured. Pay less and reach out to your health insurance professionals today. Want more facts? Check out this blog article from Kaiser Family Foundation.

A new Kaiser Family Foundation analysis finds that more than half (54% or 5.9 million) of the 10.7 million people who are uninsured and eligible to purchase an Affordable Care Act marketplace plan in 2018 could pay less in premiums for health insurance than they would owe as an individual mandate tax penalty for lacking coverage.

Within that 5.8 million, about 4.5 million (42% of the total) could obtain a bronze-level plan at no cost in 2018, after taking income-related premium tax credits into account, the analysis finds.

Most people without insurance who are eligible to buy marketplace coverage qualify for subsidies in the form of tax credits to help pay premiums for marketplace plans (8.3 million out of 10.7 million). Among those eligible for premium subsidies, the analysis finds that 70 percent could pay less in premiums than what they’d owe as a tax penalty for lacking coverage, with 54 percent able to purchase a bronze plan at no cost and 16 percent contributing less to their health insurance premium than the tax penalty they owe.

Among the 2.4 million uninsured, marketplace-eligible people who do not qualify for a premium subsidy, 2 percent would be able to pay less for marketplace insurance than they’d owe for their 2018 penalty, the analysis finds.

The Affordable Care Act’s individual mandate requires that most people have health coverage or be subject to a tax penalty unless they qualify for certain exemptions. The individual mandate is still in effect, though Congress may consider repealing it as part of tax legislation.

Consumers can compare their estimated 2018 individual mandate penalty with the cost of marketplace insurance in their area with KFF’s new Individual Mandate Penalty Calculator.

The deadline for ACA open enrollment in most states is Dec. 15, 2017.

 

You can read the original article here.

Source:

Kaiser Family Foundation (9 November 2017). "ANALYSIS: More than Half of Uninsured People Eligible for Marketplace Insurance Could Pay Less for Health Plan than Individual Mandate Penalty" [Web blog post]. Retrieved from address https://www.kff.org/health-reform/press-release/analysis-more-than-half-of-uninsured-people-eligible-for-marketplace-insurance-could-pay-less-for-health-plan-than-individual-mandate-penalty/


PPOs Dominate Despite Savings with HMOs and CDHPs

Are you searching for a detailed look at health care costs across all available health care plans? Fortunately, we have a survey that will help you gain this outlook. In this article, our partner, UBA Benefits, provides insight on the rise of health care costs and which health care plans are the most popular (costly or not).

Don't miss your chance to get your customized results.


The findings of our 2017 Health Plan Survey show a continuation of steady trends and some surprises. It’s no surprise, however, that costs continue to rise. The average annual health plan cost per employee for all plan types is $9,934, an increase from 2016, when the average cost was $9,727. There are significant cost differences when you look at the data by plan type.

Cost Detail by Plan Type

Health Plan Cost Detail by Plan Type

PPOs continue to cost more than the average plan, but despite this, PPOs still dominate the market in terms of plan distribution and employee enrollment. PPOs have seen an increase in total premiums for single coverage of 4.5% and for family coverage of 2.2% in 2017 alone.

HMOs have the lowest total annual cost at $8,877, as compared to the total cost of a PPO of $10,311. Conversely, CDHP plan costs have risen 2.2% from last year. However, CDHP prevalence and enrollment continues to grow in most regions, indicating interest among both employers and employees.

Across all plan types, employees’ share of total costs rose 5% while employers’ share stayed nearly the same. Employers are also further mitigating their costs by reducing prescription drug coverage, and raising out-of-network deductibles and out-of-pocket maximums.

More than half (54.8%) of all employers offer one health plan to employees, while 28.2% offer two plan options, and 17.1% offer three or more options. The percentage of employers now offering three or more plans decreased slightly in 2017, but still maintains an overall increase in the last five years as employers are working to offer expanded choices to employees either through private exchange solutions or by simply adding high, medium-, and low-cost options; a trend UBA Partners believe will continue. Not only do employees get more options, but employers also can introduce lower-cost plans that may attract enrollment, lower their costs, and meet ACA affordability requirements.

You can read the original article here.

Source:

Olson B. (7 November 2017). "PPOs Dominate Despite Savings with HMOs and CDHPs" [Web blog post]. Retrieved from address http://blog.ubabenefits.com/ppos-dominate-despite-savings-with-hmos-and-cdhps

 

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Understanding your Letter 226-J

Letter 226-J is the initial letter issued to Applicable Large Employers (ALEs) to notify them that they may be liable for an Employer Shared Responsibility Payment (ESRP). The determination of whether an ALE may be liable for an ESRP and the amount of the proposed ESRP in Letter 226-J are based on information from Forms 1094-C and 1095-C filed by the ALE and the individual income tax returns filed by the ALE’s employees.

What you need to do

  • Read your letter and attachments carefully. These documents explain the ESRP process and how the information received affects the computation.
  • The letter fully explains the steps to take if you agree or disagree with the proposed ESRP computation.
  • Complete the response form (Form 14764) indicating your agreement or disagreement with the letter.
  • If you disagree with the proposed ESRP liability, you must provide a full explanation of your disagreement and/or indicate changes needed on Form 14765 (PTC Listing). Return all documents as instructed in the letter by the response date.
  • If you agree with the proposed ESRP liability, follow the instructions to sign the response form and return with full payment in the envelope provided.

You may want to

  • Review the information reported on Forms 1094-C and 1095-C for the applicable year to confirm that the information filed with the IRS was accurate because the IRS uses that information to compute the ESRP.
  • Keep a copy of the letter and any documents you submit.
  • Contact us using the information provided in the letter if you have any questions or need additional time to respond.
  • Send us a Form 2848 (Power of Attorney and Declaration of Representative) to allow someone to contact us on your behalf. Note that the Form 2848 must state specifically the year and that it is for the Section 4980H Shared Responsibility Payment.

Answers to Common Questions

Why did I receive this letter?
The IRS used the information you provided on Forms 1094/5-C and determined that you are potentially liable for an ESRP.

Where did the IRS get the information used to compute the ESRP?
The IRS used form 1094/5-C filed by the ALE and the individual income tax returns of your full-time employees to identify if they were allowed a premium tax credit.

Is this letter a bill?
No, the letter is the initial proposal of the ESRP

What do I need to do?
Review the letter and attachments carefully and complete the response form by the date provided.

What do I do if the information is wrong or I disagree?
Follow the instructions in the letter to provide corrected information for consideration by the IRS. The IRS will reply with an acknowledgement letter informing you of their final determination.

Do I have appeal rights?
Yes, the acknowledgement letter that you receive will spell out all your rights, including your right to appeal.

General Information

For more info visit ACA information center for Applicable Large Employers

Here’s an excerpt from the 226J letter, and a link to the official sample.

 

Source:

IRS (9 November 2017). "Understanding your Letter 226-J" [Web blog post]. Retrieved from address https://www.irs.gov/individuals/understanding-your-letter-226-j


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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IRS to reject returns lacking health coverage disclosure

 Where does the IRS stand on ACA (Affordable Care Act)? It's time to know. Check out this article from Benefits Pro for more information.


The Internal Revenue Service has announced that for the first time, tax returns filed electronically in 2018 will be rejected if they do not contain the information about whether the filer has coverage, including whether the filer is exempt from the individual mandate or will pay the tax penalty imposed by the law on those who don’t buy coverage.

Tax returns filed on paper could have processing suspended and thus any possible refund delayed.

The New York Times reports that the IRS appears to be acting in contradiction to the first executive order issued by the Trump White House on inauguration day, in which Trump instructed agencies to “scale back” enforcement of regulations governing the ACA.

The move by the IRS reminds people that they can’t just ignore the ACA, despite the EO. Although only those lacking coverage have to pay the penalty, everyone has to indicate their insurance coverage status on their filing.

While the uninsured rate for all Americans dipped to a historic low of 8.6 percent in the first three months...5 states with lowest, highest uninsured rates

According to legal experts cited in the report, the IRS is indicating that although the administration may have leeway in how aggressively it enforces the mandate provision, it’s still in effect unless and until Congress specifically repeals it.

While many people thought they didn’t have to bother with reporting, and many insurers have raised rates anticipating that the lack of a mandate would lead to lower enrollments and higher costs for them, that’s not the case. Initially the IRS did not reject returns because the law was new.

The penalty is pretty steep; for those who don’t have coverage, it can range from $695 for an individual to a maximum of $2,085 for a family or 2.5 percent of AGI, whichever is higher. Not everyone without coverage would be penalized, though; if their income is too low or if the lowest-priced coverage costs more than 8.16 percent of their income, they’ll avoid the penalty.

That said, it’s not known how stringently the IRS will be in enforcing the mandate. But at least taxpayers will know whether they’re exempt from the penalty or whether they’re obligated to buy coverage.

 

 You can read the original article here.
Source:
Satter M. (23 October 2017). "IRS to reject returns lacking health coverage disclosure" [Web blog post]. Retrieved from address http://www.benefitspro.com/2017/10/23/irs-to-reject-returns-lacking-health-coverage-disc?ref=hp-top-stories&slreturn=1509378329

An Early Look at 2018 Premium Changes and Insurer Participation on ACA Exchanges


Each year insurers submit filings to state regulators detailing their plans to participate on the Affordable Care Act marketplaces (also called exchanges). These filings include information on the premiums insurers plan to charge in the coming year and which areas they plan to serve. Each state or the federal government reviews premiums to ensure they are accurate and justifiable before the rate goes into effect, though regulators have varying types of authority and states make varying amounts of information public.

In this analysis, we look at preliminary premiums and insurer participation in the 20 states and the District of Columbia where publicly available rate filings include enough detail to be able to show the premium for a specific enrollee. As in previous years, we focus on the second-lowest cost silver plan in the major city in each state. This plan serves as the benchmark for premium tax credits. Enrollees must also enroll in a silver plan to obtain reduced cost sharing tied to their incomes. About 71% of marketplace enrollees are in silver plans this year.

States are still reviewing premiums and participation, so the data in this report are preliminary and could very well change. Rates and participation are not locked in until late summer or early fall (insurers must sign an annual contract by September 27 in states using Healthcare.gov).

Insurers in this market face new uncertainty in the current political environment and in some cases have factored this into their premium increases for the coming year. Specifically, insurers have been unsure whether the individual mandate (which brings down premiums by compelling healthy people to buy coverage) will be repealed by Congress or to what degree it will be enforced by the Trump Administration. Additionally, insurers in this market do not know whether the Trump Administration will continue to make payments to compensate insurers for cost-sharing reductions (CSRs), which are the subject of a lawsuit, or whether Congress will appropriate these funds. (More on these subsidies can be found here).

The vast majority of insurers included in this analysis cite uncertainty surrounding the individual mandate and/or cost sharing subsidies as a factor in their 2018 rates filings. Some insurers explicitly factor this uncertainty into their initial premium requests, while other companies say if they do not receive more clarity or if cost-sharing payments stop, they plan to either refile with higher premiums or withdraw from the market. We include a table in this analysis highlighting examples of companies that have factored this uncertainty into their initial premium increases and specified the amount by which the uncertainty is increasing rates.

Changes in the Second-Lowest Cost Silver Premium

The second-lowest silver plan is one of the most popular plan choices on the marketplace and is also the benchmark that is used to determine the amount of financial assistance individuals and families receive. The table below shows these premiums for a major city in each state with available data. (Our analyses from 201720162015, and 2014 examined changes in premiums and participation in these states and major cities since the exchange markets opened nearly four years ago.)

Across these 21 major cities, based on preliminary 2018 rate filings, the second-lowest silver premium for a 40-year-old non-smoker will range from $244 in Detroit, MI to $631 in Wilmington, DE, before accounting for the tax credit that most enrollees in this market receive.

Of these major cities, the steepest proposed increases in the unsubsidized second-lowest silver plan are in Wilmington, DE (up 49% from $423 to $631 per month for a 40-year-old non-smoker), Albuquerque, NM (up 34% from $258 to $346), and Richmond, VA (up 33% from $296 to $394). Meanwhile, unsubsidized premiums for the second-lowest silver premiums will decrease in Providence, RI (down -5% from $261 to $248 for a 40-year-old non-smoker) and remain essentially unchanged in Burlington, VT ($492 to $491).

As discussed in more detail below, this year’s preliminary rate requests are subject to much more uncertainty than in past years. An additional factor driving rates this year is the return of the ACA’s health insurance tax, which adds an estimated 2 to 3 percentage points to premiums.

Most enrollees in the marketplaces (84%) receive a tax credit to lower their premium and these enrollees will be protected from premium increases, though they may need to switch plans in order to take full advantage of the tax credit. The premium tax credit caps how much a person or family must spend on the benchmark plan in their area at a certain percentage of their income. For this reason, in 2017, a single adult making $30,000 per year would pay about $207 per month for the second-lowest-silver plan, regardless of the sticker price (unless their unsubsidized premium was less than $207 per month). If this person enrolls in the second lowest-cost silver plan is in 2018 as well, he or she will pay slightly less (the after-tax credit payment for a similar person in 2018 will be $201 per month, or a decrease of 2.9%). Enrollees can use their tax credits in any marketplace plan. So, because tax credits rise with the increase in benchmark premiums, enrollees are cushioned from the effect of premium hikes.

Table 1: Monthly Silver Premiums and Financial Assistance for a 40 Year Old Non-Smoker Making $30,000 / Year
State  Major City 2nd Lowest Cost Silver
Before Tax Credit
2nd Lowest Cost Silver
After Tax Credit
Amount of Premium Tax Credit
2017 2018 % Change
from 2017
2017 2018 % Change
from 2017
2017 2018 % Change
from 2017
California* Los Angeles $258 $289 12% $207 $201 -3% $51 $88 71%
Colorado Denver $313 $352 12% $207 $201 -3% $106 $150 42%
Connecticut Hartford $369 $417 13% $207 $201 -3% $162 $216 33%
DC Washington $298 $324 9% $207 $201 -3% $91 $122 35%
Delaware Wilmington $423 $631 49% $207 $201 -3% $216 $430 99%
Georgia Atlanta $286 $308 7% $207 $201 -3% $79 $106 34%
Idaho Boise $348 $442 27% $207 $201 -3% $141 $241 70%
Indiana Indianapolis $286 $337 18% $207 $201 -3% $79 $135 72%
Maine Portland $341 $397 17% $207 $201 -3% $134 $196 46%
Maryland Baltimore $313 $392 25% $207 $201 -3% $106 $191 81%
Michigan* Detroit $237 $244 3% $207 $201 -3% $29 $42 44%
Minnesota** Minneapolis $366 $383 5% $207 $201 -3% $159 $181 14%
New Mexico Albuquerque $258 $346 34% $207 $201 -3% $51 $144 183%
New York*** New York City $456 $504 10% $207 $201 -3% $249 $303 21%
Oregon Portland $312 $350 12% $207 $201 -3% $105 $149 42%
Pennsylvania Philadelphia $418 $515 23% $207 $201 -3% $211 $313 49%
Rhode Island Providence $261 $248 -5% $207 $201 -3% $54 $47 -13%
Tennessee Nashville $419 $507 21% $207 $201 -3% $212 $306 44%
Vermont Burlington $492 $491 0% $207 $201 -3% $285 $289 2%
Virginia Richmond $296 $394 33% $207 $201 -3% $89 $193 117%
Washington Seattle $238 $306 29% $207 $201 -3% $31 $105 239%
NOTES: *The 2018 premiums for MI and CA reflect the assumption that CSR payments will continue. **The 2018 premium for MN assumes no reinsurance. ***Empire has filed to offer on the individual market in New York in 2018 but has not made its rates public.
SOURCE:  Kaiser Family Foundation analysis of premium data from Healthcare.gov and insurer rate filings to state regulators.

Looking back to 2014, when changes to the individual insurance market under the ACA first took effect, reveals a wide range of premium changes. In many of these cities, average annual premium growth over the 2014-2018 period has been modest, and in two cites (Indianapolis and Providence), benchmark premiums have actually decreased. In other cities, premiums have risen rapidly over the period, though in some cases this rapid growth was because premiums were initially quite low (e.g., in Nashville and Minneapolis).

Table 2: Monthly Benchmark Silver Premiums
for a 40 Year Old Non-Smoker, 2014-2018
State Major City 2014 2015 2016 2017 2018 Average Annual % Change from 2014 to 2018 Average Annual % Change After Tax Credit, $30K Income
California Los Angeles $255 $257 $245 $258 $289 3% -1%
Colorado Denver $250 $211 $278 $313 $352 9%  -1%
Connecticut Hartford $328 $312 $318 $369 $417 6%  -1%
DC Washington $242 $242 $244 $298 $324 8%  -1%
Delaware Wilmington $289 $301 $356 $423 $631 22%  -1%
Georgia Atlanta $250 $255 $254 $286 $308 5%  -1%
Idaho Boise $231 $210 $273 $348 $442 18%  -1%
Indiana Indianapolis $341 $329 $298 $286 $337 0%  -1%
Maine Portland $295 $282 $288 $341 $397 8%  -1%
Maryland Baltimore $228 $235 $249 $313 $392 15%  -1%
Michigan* Detroit $224 $230 $226 $237 $244 2%  -1%
Minnesota** Minneapolis $162 $183 $235 $366 $383 24%  6%
New Mexico Albuquerque $194 $171 $186 $258 $346 16%  1%
New York*** New York City $365 $372 $369 $456 $504 8%  -1%
Oregon Portland $213 $213 $261 $312 $350 13%  -1%
Pennsylvania Philadelphia $300 $268 $276 $418 $515 14%  -1%
Rhode Island Providence $293 $260 $263 $261 $248 -4%  -1%
Tennessee Nashville $188 $203 $281 $419 $507 28%  2%
Vermont Burlington $413 $436 $468 $492 $491 4%  -1%
Virginia Richmond $253 $260 $276 $296 $394 12%  -1%
Washington Seattle $281 $254 $227 $238 $306 2% -1%
NOTES: *The 2018 premiums for MI and CA reflect the assumption that CSR payments will continue. **The 2018 premium for MN assumes no reinsurance. ***Empire has filed to offer on the individual market in New York in 2018 but has not made its rates public.
SOURCE:  Kaiser Family Foundation analysis of premium data from Healthcare.gov and insurer rate filings to state regulators.

Changes in Insurer Participation

Across these 20 states and DC, an average of 4.6 insurers have indicated they intend to participate in 2018, compared to an average of 5.1 insurers per state in 2017, 6.2 in 2016, 6.7 in 2015, and 5.7 in 2014. In states using Healthcare.gov, insurers have until September 27 to sign final contracts to participate in 2018. Insurers often do not serve an entire state, so the number of choices available to consumers in a particular area will typically be less than these figures.

Table 3: Total Number of Insurers by State, 2014 – 2018
State Total Number of Issuers in the Marketplace
2014 2015 2016 2017 2018 (Preliminary)
California 11 10 12 11 11
Colorado 10 10 8 7 7
Connecticut 3 4 4 2 2
DC 3 3 2 2 2
Delaware 2 2 2 2 1 (Aetna exiting)
Georgia 5 9 8 5 4 (Humana exiting)
Idaho 4 5 5 5 4 (Cambia exiting)
Indiana 4 8 7 4 2 (Anthem and MDwise exiting)
Maine 2 3 3 3 3
Maryland 4 5 5 3 3 (Cigna exiting, Evergreen1 filed to reenter)
Michigan 9 13 11 9 8 (Humana exiting)
Minnesota 5 4 4 4 4
New Mexico 4 5 4 4 4
New York 16 16 15 14 14
Oregon 11 10 10 6 5 (Atrio exiting)
Pennsylvania 7 8 7 5 5
Rhode Island 2 3 3 2 2
Tennessee 4 5 4 3 3 (Humana exiting, Oscar entering)
Vermont 2 2 2 2 2
Virginia 5 6 7 8 6 (UnitedHealthcare and Aetna exiting)
Washington 7 9 8 6 5 (Community Health Plan of WA exiting)
Average (20 states + DC) 5.7 6.7 6.2 5.1 4.6
NOTES: Insurers are grouped by parent company or group affiliation, which we obtained from HHS Medical Loss Ratio public use files and supplemented with additional research.
1The number of preliminary 2018 insurers in Maryland includes Evergreen, which submitted a filing but has been placed in receivership.
SOURCE:  Kaiser Family Foundation analysis of premium data from Healthcare.gov and insurer rate filings to state regulators.

Uncertainty Surrounding ACA Provisions

Insurers in the individual market must submit filings with their premiums and service areas to states and/or the federal government for review well in advance of these rates going into effect. States vary in their deadlines and processes, but generally, insurers were required to submit their initial rate requests in May or June of 2017 for products that go into effect in January 2018. Once insurers set their premiums for 2018 and sign final contacts at the end of September, those premiums are locked in for the entire calendar year and insurers do not have an opportunity to revise their rates or service areas until the following year.

Meanwhile, over the course of this summer, the debate in Congress over repealing and replacing the Affordable Care Act has carried on as insurers set their rates for next year. Both the House and Senate bills included provisions that would have made significant changes to the law effective in 2018 or even retroactively, including repeal of the individual mandate penalty. Additionally, the Trump administration has sent mixed signals over whether it would continue to enforce the individual mandate or make payments to insurers to reimburse them for the cost of providing legally required cost-sharing assistance to low-income enrollees.

Because this policy uncertainty is far outside the norm, insurers are making varying assumptions about how this uncertainty will play out and affect premiums. Some states have attempted to standardize the process by requesting rate submissions under multiple scenarios, while other states appear to have left the decision up to each individual company. There is no standard place in the filings where insurers across all states can explain this type of assumption, and some states do not post complete filings to allow the public to examine which assumptions insurers are making.

In the 20 states and DC with detailed rate filings included in the previous sections of this analysis, the vast majority of insurers cite policy uncertainty in their rate filings. Some insurers make an explicit assumption about the individual mandate not being enforced or cost-sharing subsidies not being paid and specify how much each assumption contributes to the overall rate increase. Other insurers state that if they do not get clarity by the time final rates must be submitted – which has now been delayed to September 5 for the federal marketplace – they may either increase their premiums further or withdraw from the market.

Table 4 highlights examples of insurers that have explicitly factored into their premiums an assumption that either the individual mandate will not be enforced or cost-sharing subsidy payments will not be made and have specified the degree to which that assumption is influencing their initial rate request. As mentioned above, the vast majority of companies in states with detailed rate filings have included some language around the uncertainty, so it is likely that more companies will revise their premiums to reflect uncertainty in the absence of clear answers from Congress or the Administration.

Insurers assuming the individual mandate will not be enforced have factored in to their rate increases an additional 1.2% to 20%. Those assuming cost-sharing subsidy payments will not continue and factoring this into their initial rate requests have applied an additional rate increase ranging from 2% to 23%. Because cost-sharing reductions are only available in silver plans, insurers may seek to raise premiums just in those plans if the payments end. We estimate that silver premiums would have to increase by 19% on average to compensate for the loss of CSR payments, with the amount varying substantially by state.

Several insurers assumed in their initial rate filing that payment of the cost-sharing subsidies would continue, but indicated the degree to which rates would increase if they are discontinued. These insurers are not included in the Table 4. If CSR payments end or there is continued uncertainty, these insurers say they would raise their rates an additional 3% to 10% beyond their initial request – or ranging from 9% to 38% in cases when the rate increases would only apply to silver plans. Some states have instructed insurers to submit two sets of rates to account for the possibility of discontinued cost-sharing subsidies. In California, for example, a surcharge would be added to silver plans on the exchange, increasing proposed rates an additional 12.4% on average across all 11 carriers, ranging from 8% to 27%.

Table 4: Examples of Preliminary Insurer Assumptions Regarding Individual Mandate Enforcement and
Cost-Sharing Reduction (CSR) Payments
State Insurer Average Rate Increase  Requested Individual Mandate Assumption CSR Payments Assumption Requested Rate Increase Due to Mandate or CSR Uncertainty
CT ConnectiCare 17.5% Weakly enforced1 Not specified Mandate: 2.4%
DE Highmark BCBSD 33.6% Not enforced Not paid Mandate and CSR: 12.8% combined impact
GA Alliant Health Plans 34.5% Not enforced Not paid Mandate: 5.0%
CSR: Unspecified
ID Mountain Health CO-OP 25.0% Not specified Not paid CSR: 17.0%
ID PacificSource Health Plans 45.6% Not specified Not paid CSR: 23.2%
ID SelectHealth 45.0% Not specified Not paid CSR: 20.0%
MD CareFirst BlueChoice 45.6% Not enforced Potentially not paid Mandate: 20.0%
ME Harvard PilgrimHealth Care 39.7% Weakly enforced Potentially not paid Mandate: 15.9%
MI BCBS of MI 26.9% Weakly enforced Potentially not paid (two rate submissions) Mandate: 5.0%
MI Blue Care Network of MI 13.8% Weakly enforced Potentially not paid (two rate submissions) Mandate: 5.0%
MI Molina Healthcare of MI 19.3% Weakly enforced Potentially not paid (two rate submissions) Mandate: 9.5%
NM CHRISTUS Health Plan 49.2% Not enforced Potentially not paid Mandate: 9.0%, combined impact of individual mandate non-enforcement and reduced advertising and outreach
NM Molina Healthcare of NM 21.2% Weakly enforced Paid Mandate: 11.0%
NM New Mexico Health Connections 32.8% Not enforced Potentially not paid Mandate: 20.0%
OR* BridgeSpan 17.2% Weakly enforced Potentially not paid Mandate: 11.0%
OR* Moda Health 13.1% Not enforced Potentially not paid Mandate: 1.2%
OR* Providence Health Plan 20.7% Not enforced Potentially not paid Mandate: 9.7%, largely due to individual mandate non-enforcement
TN BCBS of TN 21.4% Not enforced Not paid Mandate: 7.0%
CSR:  14.0%
TN Cigna 42.1% Weakly enforced Not paid CSR: 14.1%
TN Oscar Insurance  NA (New to state) Not enforced Not paid Mandate: 0%, despite non-enforcement
CSR: 17.0%, applied only to silver plans
VA CareFirst BlueChoice 21.5% Not enforced Potentially not paid Mandate: 20.0%
VA CareFirst GHMSI 54.3% Not enforced Potentially not paid Mandate: 20.0%
WA LifeWise Health Plan of Washington 21.6% Weakly enforced Not paid Mandate: 5.2%
CSR: 2.3%
WA Premera Blue Cross 27.7% Weakly enforced Not paid Mandate: 4.0%
CSR: 3.1%
WA Molina Healthcare of WA 38.5% Weakly enforced Paid Mandate: 5.4%
NOTES: The CSR assumption “Potentially not paid” refers to insurers that filed initial rates assuming CSR payments are made and indicated that uncertainty over CSR funding would change their initial rate requests. In Michigan, insurers were instructed to submit a second set of filings showing rate increases without CSR payments; the rates shown above assume continued CSR payments. *The Oregon Division of Financial Regulation reviewed insurer filings and advised adjustment of the impact of individual mandate uncertainty to between 2.4% and 5.1%. Although rates have since been finalized, the increases shown here are based on initial insurer requests. 1Connecticare assumes a public perception that the mandate will not be enforced.
SOURCE:  Kaiser Family Foundation analysis of premium data from Healthcare.gov and insurer rate filings to state regulators.

Discussion

A number of insurers have requested double-digit premium increases for 2018. Based on initial filings, the change in benchmark silver premiums will likely range from -5% to 49% across these 21 major cities. These rates are still being reviewed by regulators and may change.

In the past, requested premiums have been similar, if not equal to, the rates insurers ultimately charge. This year, because of the uncertainty insurers face over whether the individual mandate will be enforced or cost-sharing subsidy payments will be made, some companies have included an additional rate increase in their initial rate requests, while other companies have said they may revise their premiums late in the process. It is therefore quite possible that the requested rates in this analysis will change between now and open enrollment.

Insurers attempting to price their plans and determine which states and counties they will service next year face a great deal of uncertainty. They must soon sign contracts locking in their premiums for the entire year of 2018, yet Congress or the Administration could make significant changes in the coming months to the law – or its implementation – that could lead to significant losses if companies have not appropriately priced for these changes. Insurers vary in the assumptions they make regarding the individual mandate and cost-sharing subsidies and the degree to which they are factoring this uncertainty into their rate requests.

Because most enrollees on the exchange receive subsidies, they will generally be protected from premium increases. Ultimately, most of the burden of higher premiums on exchanges falls on taxpayers. Middle and upper-middle income people purchasing their own coverage off-exchange, however, are not protected by subsidies and will pay the full premium increase, switch to a lower level plan, or drop their coverage. Although the individual market on average has been stabilizing, the concern remains that another year of steep premium increases could cause healthy people (particularly those buying off-exchange) to drop their coverage, potentially leading to further rate hikes or insurer exits.

Methods

Data were collected from health insurer rate filing submitted to state regulators. These submissions are publicly available for the states we analyzed. Most rate information is available in the form of a SERFF filing (System for Electronic Rate and Form Filing) that includes a base rate and other factors that build up to an individual rate. In states where filings were unavailable, we gathered data from tables released by state insurance departments. Premium data are current as of August 7, 2017; however, filings in most states are still preliminary and will likely change before open enrollment. All premiums in this analysis are at the rating area level, and some plans may not be available in all cities or counties within the rating area. Rating areas are typically groups of neighboring counties, so a major city in the area was chosen for identification purposes.


New Regulations Broadening Employer Exemptions to Contraceptive Coverage: Impact on Women


You can read the original article here.

Source:

Sobel L., Salganicoff A., Rosenzweig C. (6 October 2017). "New Regulations Broadening Employer Exemptions to Contraceptive Coverage: Impact on Women" [Web Blog Post]. Retrieved from address https://www.kff.org/womens-health-policy/issue-brief/new-regulations-broadening-employer-exemptions-to-contraceptive-coverage-impact-on-women/

The Trump Administration has issued new regulations that significantly broaden employers’ ability to be exempt from the Affordable Care Act’s (ACA) contraceptive coverage requirement.  The regulation opens the door for any employer or college/ university with a student health plan with objections to contraceptive coverage based on religious beliefs to qualify for an exemption. Any nonprofit or closely-held for-profit employer with moral objections to contraceptive coverage also qualifies for an exemption. Their female employees, dependents and students will no longer be entitled to coverage for the full range of FDA approved contraceptives at no cost.

On October 6, 2017, the Trump Administration issued two new regulations greatly expanding the types of employers that may be exempt from the Affordable Care Act’s (ACA) contraceptive coverage requirement.  These regulations are a significant departure from the Obama-era regulations that only granted an exception to houses of worship.  One of the regulations allows nonprofits or for-profit employer with an objection to contraceptive coverage based on religious beliefs to qualify for an exemption and drop contraceptive coverage from their plans.  The other regulation also exempts all but publicly traded employers with moral objections to contraception from rule. These new policies, effective immediately, also apply to private institutions of higher education that issue student health plans. The immediate impact of these regulations on the number of women who are eligible for contraceptive coverage is unknown, but the new regulations open the door for many more employers to withhold contraceptive coverage from their plans.

New regulations from the Trump administration greatly expand exemption from #ACA contraceptive coverage rule

Contraceptive coverage under the ACA has made access to the full range of contraceptive methods affordable to millions of women. This provision is part of a set of key preventive services that has been identified by the Health Resources and Services Administration (HRSA) for women that must be covered without cost-sharing. Since it was first issued in 2012, the contraceptive coverage provision has been controversial. While very popular with the public, with over 77% of women and 64% of men reporting support for no-cost contraceptive coverage, it has been the focus of litigation brought by religious employers, with two cases (Zubik v Burwell and Burwell v Hobby Lobby)  reaching the Supreme Court. This brief explains the contraceptive coverage rule under the ACA, the impact it has had on coverage, and how the new regulations issued by the Trump Administration change the contraceptive coverage requirement for employers and affect women’s coverage.

How do the new regulations change contraceptive coverage requirements for employers?

Since they were announced in 2011, the contraceptive coverage rules have evolved through litigation and new regulations. Most employers were required to include the coverage in their plans. Houses of worship could choose to be exempt from the requirement if they had religious objections. This exception meant that women workers and female dependents of exempt employers did not have guaranteed coverage for either some or all FDA approved contraceptive methods if their employer had an objection. Religiously affiliated nonprofits and closely held for-profit corporations were not eligible for an exemption, but could choose an accommodation. This option was offered to religiously affiliated nonprofit employers and then extended to closely held for-profitsafter the Supreme Court ruling in Burwell v. Hobby Lobby. The accommodation allowed these employers to opt out of providing and paying for contraceptive coverage in their plans by either notifying their insurer, third party administrator, or the federal government of their objection. The insurers were then responsible for covering the costs of contraception, which assured that their workers and dependents had contraceptive coverage while relieving the employers of the requirement to pay for it.

As of 2015, 10% of nonprofits with 5,000 or more employees had elected for an accommodation without challenging the requirement. This approach, however, has not been acceptable to all nonprofits with religious objections.1 In May 2016, the Supreme Court remanded Zubik v. Burwell, sending seven cases brought by religious nonprofits objecting to the contraceptive coverage accommodation back to the respective district Courts of Appeal. The Supreme Court instructed the parties to work together to “arrive at an approach going forward that accommodates petitioners’ religious exercise while at the same time ensuring that women covered by petitioners’ health plans receive full and equal health coverage, including contraceptive coverage.”2

On October 6, 2017, the Trump Administration issued new regulations greatly expanding eligibility for the exemption to all nonprofit and closely-held for-profit employers with objections to contraceptive coverage based on religious beliefs or moral convictions, including private institutions of higher education that issue student health plans (Figure 1).  In addition, publicly traded for-profit companies with objections based on religious beliefs also qualify for an exemption. There is no guaranteed right of contraceptive coverage for their female employees and dependents or students. Table 1 presents the changes to the contraceptive coverage rule from the Obama Administration in the new Interim Final regulations issued by the Trump Administration.

Figure 1: Employers Objecting to Contraceptive Coverage: Exemptions and Accommodations Under the Trump Administration Regulations

The accommodation will be available to employers that previously qualified for the accommodation.  They now will also have the choice of an exemption. The federal departments issuing the regulations posit that these new rules will have limited impact on the number of women losing contraceptive coverage.   However, it is not clear how many employers previously utilizing the accommodation will now opt for an exemption, resulting in the loss of contraceptive coverage for their employees and dependents.  In addition, there are also an unknown number of organizations that were not previously eligible for either the accommodation or exemption that may now opt for an exemption. These new regulations create two new categories of employers who can now qualify for an exemption or can voluntarily chooses an accommodation:  1) publicly traded for-profit companies with a religious objection and 2) nonprofit and closely held for-profit employers who have a moral objection to contraceptives, a considerably larger pool of employers than when the exemption was available only to those who were employees of a house of worship or who were eligible for an accommodation in the past.

Table 1: Summary of Changes in the Contraceptive Coverage Regulations for Objecting Entities
  Obama Administration
August 2012 to October 5, 2017
Trump Administration
Effective October 6, 2017
What types of contraceptives must plans cover without cost-sharing? At least one of each of the 18 FDA approved contraceptive methods for women, as prescribed, along with counseling and related services must be covered without cost-sharing. No change
Are any employers “exempt” from the contraceptive mandate?
  • Religious institutions defined as “houses of worship”
  • Grandfathered plans
  • No notice to employees is required. Women workers and female dependents must pay for their own contraceptives.
  • Religious institutions defined as “houses of worship”
  • Grandfathered plans
  • Nonprofit or  for-profit employers (including publicly traded companies), insurers, or private colleges or universities that issue student insurance plans with a religious objection to contraceptive coverage
  • Nonprofit or closely held for-profit employers, insurers, or private colleges or universities that issue student insurance plans with a moralobjection to contraceptive coverage
  • Notice is only required if the plan previously included contraceptive coverage. Women workers and female dependents must pay for their own contraceptives.
Who pays for contraceptive coverage for employees of organizations receiving an exemption?
  • The cost of contraceptives is borne by women workers and female dependents.
  • There is no guarantee of contraceptive coverage for employees of an exempt organization.
  • The employer may choose to cover some methods, but has no obligation to cover all 18 FDA methods without cost sharing
No change

What type of employers may seek an “accommodation” to avoid paying for contraceptives in their plans?  
  • Closely held for-profit corporations and religiously affiliated nonprofits with religious objections to contraception can opt out of providing and paying for contraceptive coverage
  • Notice must be provided to either their insurer, third party administrator, or the federal government of their objection.
  • Women workers and female dependents receive no cost contraceptive coverage.
  • Any entity (except for houses of worship) eligible for an exemption can choose the accommodation instead of the exemption.
  • Notice must be provided to either their insurer, third party administrator, or the federal government of their objection.
  • Women workers and female dependents receive no cost contraceptive coverage.
Who pays for contraceptive coverage for employees of organizations receiving an accommodation?
  • Insurance companies of firms obtaining an accommodation must pay for contraceptive coverage.
  • Third-party administrators (TPA) of self-funded health plans must cover the costs of contraceptives for employees. The costs of the benefit are offset by reductions in the fees the TPA pays to participate in the federal exchange.
No change
When can entities change from an accommodation to an exemption? N/A
  • When an employer or private college or university currently using the accommodation opts for an exemption, the revocation of contraceptive coverage will be effective on the first day of the first plan year that begins 30 days after the date of the revocation or 60 days notice may be given in a summary of benefits statement.
  • The issuer or third party administrator is responsible for providing the notice to the beneficiaries.

How has the contraceptive coverage rule affected women?

Contraceptive use among women is widespread, with over 99% of sexually-active women using at least one method at some point during their lifetime.3 Contraceptives make up an estimated 30-44% of out-of-pocket health care spending for women.4 Since the implementation of the ACA, out-of-pocket spending on prescription drugs has decreased dramatically (Figure 2). The majority of this decline (63%) can be attributed to the drop in out-of-pocket expenses on the oral contraceptive pill for women.5 One study estimates that roughly $1.4 billion dollars per year in out-of-pocket savings on the pill resulted from the ACA’s contraceptive mandate.6  By 2013, most women had no out-of-pocket costs for their contraception, as median expenses for most contraceptive methods, including the IUD and the pill, dropped to zero.7

Figure 2: The Contraceptive Coverage Policy Has Had a Large Impact on Out-Of-Pocket Spending in a Short Amount of Time

This provision has also influenced the decisions women make in their choice of method. After implementation of the ACA contraceptive coverage requirement, women were more likely to choose any method of prescription contraceptive, with a shift towards more effective long-term methods.8  High upfront costs of long-acting methods, such as the IUD and implant, had been a barrier to women who might otherwise prefer these more effective methods.  When faced with no cost-sharing, women choose these methods more often9, with significant implications for the rate of unintended pregnancy and associated costs of childbirth.10

Finally, decreases in cost-sharing were associated with better adherence and more consistent use of the pill. This was especially true among users of generic pills.  One study showed that even copayments as low as $6 were associated with higher levels of discontinuation and non-adherence,11 increasing the risk of unintended pregnancy.

Do states with no-cost contraceptive coverage laws allow exemptions to objecting entities?

The federal standards under Affordable Care Act created a minimum set of preventive benefits that applied to most health plans regulated by the federal government (self-funded plans, federal employee plans) and states (individual, small and large group plans), including contraceptive coverage for women with no cost-sharing.  States have also historically regulated insurance, and many have had mandated minimum benefits for decades. State laws, however, have more limited reach in that they only apply to state regulated fully insured plans, do not have jurisdiction over self-funded plans, where 61% of covered workers are insured.12 In self-funded plans, the employer assumes the risk of providing covered services and usually contracts with a third party administrator (TPA) to manage the claims payment process. These plans are overseen by the Federal Department of Labor under the Employer Retirement Income Security Act (ERISA) and are only subject to federally established regulations.13  The ACA sets a minimum standard of coverage for preventive services for all plans. However, state laws regulating insurance, including contraceptive coverage, can require fully insured plans to provide coverage beyond the federal standards.

Eight states have strengthened and expanded the federal contraceptive coverage requirement (CA, IL, MD, ME, NV, NY, OR, VT).  Another 20 states have contraceptive equity laws that require plans to cover contraceptives if they also provide coverage for prescription drugs but they do not necessarily require coverage of all FDA-approved contraceptives or ban cost-sharing (Figure 3).

Figure 3: Many States Have Contraceptive Coverage Requirements

Many of the 28 states that have passed contraceptive coverage laws (both equity and no-cost coverage) have a provision for exemptions, but the laws vary from state to state and only apply to fully insured plans.  This means that there may be a conflict between the state and federal requirements when it comes to religious exemptions.  In some states with a contraceptive coverage requirement, some employers who are eligible for an exemption under federal law will not qualify for an exemption under state law (Table 2). Employers in those states will have to have to meet the standards established by their state even though they may qualify for an exemption based on the new federal regulations.  This conflict may set the stage for future litigation.

Table 2: State Requirements for No-Cost Contraceptive Coverage
StateDate Effective Applies to Coverage required without cost sharing Exemptions allowed
  Private plans Medicaid With RX all FDA approved OTC Vasectomy Religious Moral
CaliforniaJanuary 2015 X MCOs X Narrowly defined nonprofit religious employers None
IllinoisJanuary 2017 X X X
except male condoms
Any employer, or insurer with a religious objection Any employer, or insurer with a moral objection
MarylandJanuary 2018 X X X X X Religious organizations if the coverage conflicts with the organization’s bona fide religious beliefs and practices None
MaineJanuary 2019 X X Narrowly defined nonprofit religious employers None
NevadaJanuary 2018 X X X Insurers affiliated with a religious organization None
New YorkAugust 2017 X X Narrowly defined nonprofit religious employers* None
OregonAugust 2017 X X X Narrowly defined nonprofit religious employers None
VermontOctober 2016 X X – and all other public health assistance programs X X None None
NOTES: *Requires the insurer to offer a rider to policyholders so that women will have contraceptive coverage.
SOURCE: Kaiser Family Foundation analysis of state laws and regulations.

Conclusion

The Trump Administration’s new regulations substantially expand the exemption to nonprofit and for-profit employers, as well as to private colleges or universities with religious or moral objections to contraceptive coverage. It is unknown how many of these employers and colleges will maintain coverage through the accommodation as before and how many will now opt for the exemption leaving their students, employees and dependents without no-cost coverage for the full range of contraceptive methods. As a result of the new regulation, choices about coverage and cost-sharing will be made by employers and private colleges and universities that issue student plans. For many women, their employers will determine whether they have no-cost coverage to the full range of FDA approved methods.  Their choice of contraceptive methods may again be limited by cost, placing some of the most effective yet costly methods out of financial reach.

You can read the original article here.

Source:

Sobel L., Salganicoff A., Rosenzweig C. (6 October 2017). "New Regulations Broadening Employer Exemptions to Contraceptive Coverage: Impact on Women" [Web Blog Post]. Retrieved from address https://www.kff.org/womens-health-policy/issue-brief/new-regulations-broadening-employer-exemptions-to-contraceptive-coverage-impact-on-women/


IRS Releases Draft Forms and Instructions for 2017 ACA Reporting

Here are the latest updates in ACA Reporting, including the released IRS draft forms and instructions.


Read the original article here.

Source:

Capilla D. (5 October 2017). "IRS Releases Draft Forms and Instructions for 2017 ACA Reporting" [Web Blog Post]. Retrieved from address http://blog.ubabenefits.com/irs-releases-draft-forms-and-instructions-for-2017-aca-reporting-1

 

Under the Patient Protection and Affordable Care Act (ACA), individuals are required to have health insurance while applicable large employers (ALEs) are required to offer health benefits to their full-time employees.

Reporting is required by employers with 50 or more full-time (or full-time equivalent) employees, insurers, or sponsors of self-funded health plans, on health coverage that is offered in order for the Internal Revenue Service (IRS) to verify that:

  • Individuals have the required minimum essential coverage,
  • Individuals who request premium tax credits are entitled to them, and
  • ALEs are meeting their shared responsibility (play or pay) obligations.

2017 Draft Forms and Instructions

Draft instructions for both the 1094-B and 1095-B and the 1094-C and 1095-C were released, as were the draft forms for 1094-B1095-B1094-C, and 1095-C. There are no substantive changes in the forms or instructions between 2016 and 2017, beyond the further removal of now-expired forms of transition relief.

In past years the IRS provided relief to employers who make a good faith effort to comply with the information reporting requirements and determined that they will not be subject to penalties for failure to correctly or completely file. This did not apply to employers that fail to timely file or furnish a statement. For 2017, the IRS has unofficially indicated that the “good faith compliance efforts” relating to reporting requirements will not be extended. Employers should be ready to fully meet the reporting requirements in early 2018 with a high degree of accuracy. There is however relief for de minimis errors on Line 15 of the 1095-C.

The IRS also confirmed there is no code for the Form 1095-C, Line 16 to indicate an individual waived an offer of coverage. The IRS also kept the “plan start month” box as an optional item for 2017 reporting.

Employers must remember to provide all printed forms in landscape, not portrait.

When? Which Employers?

Reporting will be due early in 2018, based on coverage in 2017.

For calendar year 2017, Forms 1094-C, 1095-C, 1094-B, and 1095-B must be filed by February 28, 2018, or April 2, 2018, if filing electronically. Statements to employees must be furnished by January 31, 2018. In late 2016, a filing deadline was provided for forms due in early 2017, however it is unknown if that extension will be provided for forms due in early 2018. Until employers are told otherwise, they should plan on meeting the current deadlines.

All reporting will be for the 2017 calendar year, even for non-calendar year plans. The reporting requirements are in Sections 6055 and 6056 of the ACA.

 

For an at-a-glance chart of all reporting requirements, as well as information on penalties for failure to file, 6055 requirements and instructions for certain boxes/lines on 1095C, request UBA’s ACA Advisor, “IRS Releases Draft Forms and Instructions for 2017 ACA Reporting“.

 

Read the original article here.

Source:

Capilla D. (5 October 2017). "IRS Releases Draft Forms and Instructions for 2017 ACA Reporting" [Web Blog Post]. Retrieved from address http://blog.ubabenefits.com/irs-releases-draft-forms-and-instructions-for-2017-aca-reporting-1