Tag Archives: health insurance

2018 ACA Update – Clearing up Common Misunderstandings

It’s seems like only yesterday that the Affordable Care Act (aka ACA, ObamaCare) was signed into law.   In fact, the law will celebrate it’s 8th anniversary on March 23, 2018…….and it was a big deal.   Yet, in all of this time and all of the front page conversations, so much is still not clear to so many.

Many misunderstandings are creating frustration for individuals, employees and employers.   Insurance and Benefit professionals spend countless hours providing service and guidance to those caught up in this ongoing learning curve.   I would like to take some time to highlight the most common, and often costly misunderstandings.

For Employers

The Employer Mandate to provide Affordable Coverage is in effect

Employers (and Controlled Groups) with 50 or more Full Time Equivalents must offer their eligible full-time employees health insurance that provides minimum essential coverage that is both affordable and provides minimum value.   Just this week, the IRS has released information to remind employers that they are going to be collecting penalties.   The Wall Street Journal (2-13-18) is reporting here that:

The financial impact on businesses could be significant. The nonpartisan Congressional Budget Office estimated in 2014 that companies would owe about $139 billion in penalties from fiscal 2016 to 2024.

“There are penalties of three, four, five million dollars,” said Alden Bianchi, an attorney at the firm Mintz Levin. “There is a smaller group of employers that really didn’t understand how the rules applied and didn’t offer coverage or sufficient coverage in 2015. … To a smaller company, a half-million is an existential threat.”

Employers need to offer coverage to at least 95% of their eligible full-time employees.  Penalties apply for non-compliance.  For additional information on affordability,  minimum value and penalties please contact Paula Wilson at paula@paulawilson.com.     (IRS Employer Mandate Penalties)

The Individual Mandate is still  in effect

Employers should remind their employees that the individual mandate is still in effect as well as the penalties for non-compliance through the end of calendar year 2018.  Employees declining coverage in 2018 should be warned.  Employers accepting employee declinations without proper counsel should provide time for employees to meet with your benefit advisor/agent.  We are always happy to provide this time to our clients.

Overwhelmed by 1095-C Tracking and Reporting on your Age Rated plan?

Employers subject to 1095 reporting in an age rating environment can often make their life easier with a bit of planning.    Employers offering more generous plans can often offer a Bronze level plan at no copay to the employees.   This would allow the 1095-C to be easily completed as the cost to the employee for a qualified plan would always be $0.  Because California considers groups from 1-100 to be small group, this reporting nightmare is a reality for employers with 51-100 employees.

Employers can make this reporting easier with thoughtful benefit planning and the advice of experienced benefit agents.

Plan Documents (WRAP) Documents

Employers must update and distribute a complete set of Plan Documents to all employees per ERISA.  These important Plan Documents will include but are not limited to Summary Plan Descriptions, Summaries of Benefits and Coverage as well as other documents needed based on your employee benefit package.   Simply offering an Employer Sponsored medical insurance plan constitutes an Employee Welfare Plan and you must comply with ERISA.  Be sure to ask your agent or administrator about these documents.

For Individuals and Employees

Preventive Care is covered at 100%. 

I am still shocked at the number of people who are not taking advantage of this benefit, if not for themselves….for their children.  As a society, we are living in a time when lifestyle related diseases can be caught and dealt with if you just know your numbers.  Make time to know your numbers.

Surprisingly, we spend a good part of our customer service hours explaining uncovered expenses that many thought were covered under this important benefits.   Blue Shield recently provided an excellent illustration to understand the coverage.  You can find that link here.

Even if you’re feeling fine, scheduling an appointment with your doctor for preventive care services is important. Through a preventive exam and routine health screenings, your doctor can determine your current health status and detect early warning signs of more serious, costly problems.

What’s covered in a preventive care visit

During your visit, your doctor will determine what tests or health screenings are right for you based on factors such as your age, gender, health status, and health and family history.  Plus, your medical plan covers 100% of the costs for preventive health services when care is provided through network providers. Be sure your physician understands your expectations of the free visit and testing.   IF the physician orders tests that are not covered within the limitations of ACA YOU WILL BE responsible for the charges.

What’s not considered a preventive care visit

If you discuss new medical concerns or a current illness, the entire visit may be considered a medical treatment visit and would not be covered as preventive care.  Copayments, Deductibles and Coinsurance will apply. You will be required to pay the plan’s physician office copayment or coinsurance.

The complete definition and detail of what is covered under the Preventive Benefits can be found at  the Healthcare.gov website here.

If your employer offers you Affordable and Minimum Value Coverage you cannot go to the State or Federal Exchange and receive a subsidy.

Employers may charge the employee up to 9.69% of his pay as a contribution to the employee only coverage.   Employees often look to the State Exchanges for lower cost coverage when employers require employee contribution.

You will be asked to make repayment if you are receiving subsidies in error.   This often occurs when:

The Employee does not disclose the offer of the employer based coverage at the time of application to the Marketplace, or,

The Employee does not advise the Marketplace in which they are already enrolled of any change of income or employment status to justify continued eligibility.

It is important that employers utilize their benefits professional/agent at the time of open enrollment to review needs and address these issues with the employee.

 

Paula Wilson, RHU, REBC is a insurance agent specializing in benefits for employers in the Southern California area.

 


The Next ACA Victim – How Mid Sized Employers are about to be blindsided

The Next ACA Victim – How Mid Sized Employers are about to be blindsided

Paula L. Wilson, RHU, REBC

Paula L. Wilson, Inc.

updated June 2016

Much has been said about the market changes brought about during the implementation of ACA and how those changes continue to affect how health insurance is distributed.  From large corporations to Mom and Pop shops, employers are doing what they can to keep the coverage flowing.  When you know where you stand, it’s easy to plan ahead for predictable market changes and upcoming compliance issues.

However, a large sector of the current “employer market” is about to be blindsided with more change at once than any other employer sector since the inception of ACA.  These employers think they are members of the large employer market and are acting as such.  Nothing could be further from the truth.  No market sector is less prepared for the change ahead.  Employers with 51-99 employees are being thrown into the small group market while simultaneously becoming subject to the large employer “Shared Responsibility” and “Reporting” mandate.  California insurers, so far, are not offering to relieve these employers from the age rating that is sure to wreak havoc on their administration and 1095 IRS reporting duties.

In the past, these “51-99 employers” have enjoyed the ability to negotiate rate and benefit levels for their employees.   Benefits are designed for their specific employee population and rates are computed and issued on a “composite” basis.  (Meaning one rate applies to all employees regardless of age.)  Strategies are then put in place to help keep employees healthy to reduce claims in order to maintain the high ground during annual rate negotiations.

On January 1, 2016, employers with 51-99 employees are going to find themselves unprepared for their new market and compliance requirements.  Just a few of their new required tasks include:

1) Determine PPACA impact with the completion of their measurement period tracking, per IRS guidelines.

2) Complete new PPACA required reporting forms IRS 1095-C and 1094-C for every month of 2015.  Conscientious tracking now will save overwhelming re-creation of the data later.    The  IRS has prepared a 14-page instruction manual for completion of these forms.  .

3) Go to market in the newly expanded Small Group Market to find things work a bit different.  One thing is certain – you can’t keep your current plan.   In the small group market, rates are non-negotiable, plans are limited to four approved “metal” tiers as determined by ACA guidelines and billed rates are based on the actual age of each employee! ( In one year age brackets.)

4) Determine a plan (or plans) that are appropriate and competitive for all* of your employees based on the “affordability” rules of ACA.   This large employer now has 45+ age rating categories PER PLAN!   Rethinking your contribution scenario that fulfills ACA rules, is palatable to your employees, AND makes monthly tracking of the 1095-C detail reasonably possible will take some time and specialized knowledge.

This is overwhelming, but not an impossible task when prepared and fully armed with the facts.  However, the lack of media coverage of this potential time bomb for mid sized employers is tragic.  Health Insurance Agents, Financial and Tax Advisors are already going to be overwhelmed during the national open enrollment when all of this hits during 4th quarter and these employers are out there scrambling for help.   The time to help these employers is now.  The time for them to help themselves by seeking proper planning advice is now!

The American Academy of Actuaries predict that this new segment of the redefined “Small Group Market” will account for 30% of that new small group market.  The impact on the small group market could be catastrophic in short order.   Employers thrown into this new system have some decisions to make.   Historically, employers with high risk, high claim populations tend to head for the fully insured market.   Employers with healthier populations may consider the self funding options available to them.   This adverse selection will put rapid upward pressure on small group market rates.

Keeping in mind that we entering a national election cycle, all of this is subject to delays, twists and turns over the next few months. Getting to the right benefits expert for planning advice is imperative for this sector.   We should all be working to get this word out now!

Paula L. Wilson, RHU, REBC is owner/agent of Paula L. Wilson, Inc. An insurance agency specializing in employee benefit in Southern California since 1986.  paula@paulawilson.com  951-694-1009


My thoughts on the status of Wellness Programs

With a bit a research you will find that nearly every report, from bloggers to Rand, clearly report that Wellness Programs that have a Disease Management program AND effectively communicates with the employees, will see the most return for their investment.

Spending a lot of money on Healthy Lifestyles is warm and fuzzy and may help the country out in the long run, but there isn’t so much of a bang for a buck.  Especially for the average 100 employee group.

True wellness companies just aren’t in that small employer (<500) market any longer and the costs associated with putting one together just don’t make sense.   

In a time where the competition lies in the bells and whistles, most carriers have built in a wellness program for their clients.   Anthem Blue Cross of California has one of the best I have seen.  Their Wellness Program is called “Time Well Spent” is turnkey.   It provides the employer and the employee with the following:

  • Wellness calendar with links to print or download 3 different flyers on the topic of the month.  This allows for quick distribution to employees.
  • Provides an introductory brochure to let employees know that it is time to get online and create an account for their health plan.
  • They are reminded to get their annual exam so they know their numbers.  Risk Assessments require current cholesterol, blood pressure and sugar
  • Provides a free Health Risk Assessment.
  • Employees with identified risks will be contacted in some manner by the carrier to jump into their disease management program.

I cannot detail the cornucopia of information that is available through this program.  I can say that Anthem of California’s is very impressive and user friendly.

Frankly, most carriers have these program.   In order to stand out to our clients, I try to pass the information on to both employer and employees.  Although, without the commitment from the employers, they won’t get much traction.   In the case of Anthem Blue Cross, it is VERY simple for an employer to decide if this effort will work for them.   I only need print out the calendar, a few sample brochures, some of the reports backing up the efficacy of this particular route and get them going.    

During this time of national change, employees are a bit worried about hearing from HR departments and Benefit Agents on their health plans.  Employers looking for ways to bring some sunshine into their benefit program should consider this opportunity to spread a little positive action.


ObamaCare: It’s not Working, It’s Winning

Professional health insurance agents have a front row seat to the carnage that ObamaCare is creating as it rolls out on top of Americans.   We are the referees on the field.  Over the next year, as our small business clients receive their 2014 cancellation notices, which every single one of them will, the pain inflicted is going to be hard to watch and a constant moving target to overcome.   Nonetheless, we will fight to continue to deliver a winning result.

I’ve always thought of my “game” as another way of casually addressing my profession, a profession that I take very seriously.   I have worked very hard for over 30 years to ensure the financial health and access to health care for all of my clients.   There is an army of agents in this country who have remained very involved in health care legislation over the years to protect our clients from what is happening now.  Because of this ongoing commitment to be involved on a daily basis, we also know this law better than anyone.   No professional agent has been surprised by anything that has unfolded in the past 2 years as issues come to light.  The complete and total destruction of access to affordable health care is in process.   Continued financial health is being ripped from the hands of all of my clients.

As the dismantling continues and public outcry ensures, the administration makes minor gestures to settle the roar to a rumble.   Moves to extend coverage on non-grandfathered plans, delaying the penalties of the employer mandate and blaming the chaos on the computer system are nothing more than distractions.

I truly believe that President Obama, his administration and their followers think this is a real “game” in the true sense of the word.  Their primary goal is not to expand coverage to the masses or reduce the cost of health insurance.   If it were, they would hang their heads in shame, not to be seen in public for years.     Their goal is to win.  They are out banging their chests in victory because they are winning the game.

Where there are winners, there are losers.   Insurance agents see the effect of the bullying that has been perpetrated on the losing public every day.  The scene plays out over and over with every phone call and every visit.   An insured comes in because their plan has been cancelled and they need to replace it with an “ObamaCare approved metallic plan”.   In most instances, the new market presents a plan of options that include twice the premium, twice the out-of-pocket risk and an overall reduction in benefits.

Consumers who have long become accustomed to dozens of choices in health care options, are shocked to find only 4 basic choices in this new world.   It is truly heartbreaking as I watch the client walk in and go through the phases of denial.   Their shock and anger are quickly turned into acceptance as I pat their hand and assure them that I am showing them all of their choices.  There is no longer anywhere to go for reasonable options.  At least we are around to show them the entire market.  (Exchanges only show you exchange plans)

When I get to the point in the conversation where I have to tell them that more than half of the top rated physician and hospital groups are no longer included within their plan, they shrug their shoulders in complete and total surrender.   They complete the application process and move on with their day.    The problems they are about to face as they enter the exchange or overloaded insurer online systems is not their biggest problem.   The technical problems are just convenient cover for the myriad of real problems.   Their real problem is that they are living in a country that is retreating and accepting the beating that has been unleashed on them.  This isn’t only redistribution of wealth; it’s retaliation on the successful middle class.

As I move around my business circles, I am amazed by how many people think this is all just going to go away and be fixed.   American’s who think people are going to stand up and fight this national plague need to think again.   No one is fighting this!  Every single person that goes through process this gives up.  They have no choice but to accept the increases in premium, thousands of dollars more in out-of-pockets costs and in most of my cases, a complete loss of access to the care that they and their children deserve.

If you are in the “sit back and do nothing while it implodes” crowd, you are in the same surrender mode.   Have you considered what an implosion looks like?   You need only to understand that many of the winners will lose their jobs, face a reduction in hours or be forced in and out of MediCaid as the Exchanges find their sweet spot.   Thousands will find themselves on a medical access seesaw.   At that point, we will all be on the losing team.

Has anyone stopped to consider what the effect of this complete surrender to a government imposed hardship is going to do to the working class people in this country?   My clients are the majority.  These are not people asking for handouts from the Exchanges or MediCaid.   These are the people who make those programs solvent.   They are too busy working to fight.

This President and his followers are nothing more than schoolyard bullies, dancing in the end-zone as the rest cower en masse.   They got their win and they don’t care about the pain they are inflicting on the multitudes or the type of transformation of America they are causing.     

Mr. President.  Congratulations on your win.  What are you going to do next?


Who Canceled My Insurance Policy?

If you have a private health plan for you and your family, you will probably receive a notice of plan cancellation shortly.   Please don’t panic and understand that it is all part of the metamorphosis we are all going to be forced to take over the next year.

Remember that pledge:  “If you like your insurance, you can keep it”?  Well, that is a dream for most of the population in the real world.    In reality, any policy written, rewritten or changed substantially since March 23, 2010 is considered NOT grandfathered and therefore will be cancelled and replaced with an ObamaCare approved plan.   If you hear nothing else I write, hear this:   Just because Obama approves it doesn’t mean you will.  And you must review the plan details.

In the new world, choices will be reduced DRASTICALLY.   Your new world will consist of cookie cutter plans with much smaller physician networks.   In California,  PPOs will be replaced widely with EPOs.   Get used to that term because it is going to take hold.   A PPO covers you if you use the a PPO physician while allowing lesser coverage if you don’t use a PPO physician.  An EPO ONLY covers you if you use a network physician.   If you don’t, you are not covered.   This limitation along with a much reduced list of PPO physicians greatly reduces your choices in where you get care.

Why did my family costs go so high?

One of the MAJOR changes with ObamaCare is how a family rate is put together.   In the past, a family could have 3 to 10 members and all be eligible for the same rate.   Not so any longer.   All family participants are now rated separately.   Remember that 22  year old you put back on your plan just because you could?   That adult child will now carry and adult rate to the table with them.   Surprise!

Back to the cancellation letter you are about to receive.  In essence, ObamaCare requires ALL non grandfathered individual policies to be cancelled 1-1-14.  BUT, that doesn’t necessarily mean you don’t have coverage. Your carrier should move you to a plan closest to your current benefits or cost.  Which benchmark they use is up to the carrier.  If you don’t like where they put you, look at the options they give you.  If you plan to make a change, don’t sit on it. You can only make a change during this national open enrollment and annually at future open enrollments. (Again, there are exceptions for qualifying events.)

To recap:

  • You probably can’t keep your plan.
  • Watch for changed family deductibles, higher out of pocket maximums, far higher specialty drug costs, and many hidden co-payments.
  • You might not be able to keep your doctor.
  • Don’t forget to take the time to inquire about the new physician list.  IT WILL BE SMALLER.
  • You aren’t going to be free to change whenever you want.

A guarantee issue market comes with limits.  Rule vary case by case.   This first Open Enrollment will run from October 1, 2013 to 3-31-14.   In subsequent years, Open Enrollment will be the fourth quarter of every year for January 1 effective dates.

There will be new choices.  Use a GOOD insurance agent to guide you.  Look for years of experience and specialty in health care.   Many newbies are picking up overnight expert designations and titles.   Don’t fall for the scam.   A good agent will have all the information available for private market and government subsidized plans through your State Exchange.   If they don’t, use Find an Agent at http://www.NAHU.org.

Since subsidies are only available if you buy a cookie cutter plan through your State Exchange, you should advise the agent you would like to inquire about the Exchange.  Any agent worth a nickel will be able to give you a good estimate of your subsidy.

Whatever you do.  DO NOT go directly to an Exchange.   They will be staffed with less educated and completely non accountable employees.  Agents are free and will explore ALL of your options, so use them.

If you get to keep your plan and you like it, stay there and let the guinea pigs work out the kinks for a few years.  I know I am holding on to mine!

Paula L. WIlson, RHU, REBC

http://www.paulawilson.com

paula@paulawilson.com


$5,000 Health Insurance Subsidy…for you?

While PPACA is simmering in the Supreme Court, the U. S. Treasury Department has been busy defining who will be the recipient of the Health Insurance Premium Tax Credits (HIPTC).   These new regulations were published last week and can be seen in their entirety here.

Who gets the subsidy?

As PPACA outlines, individual and families with incomes from 100% to 400% of the Federal Poverty Level (FPL) are eligible for the credit.   (In 2011 dollars, eligible incomes would fall between $22,350 and $89,400)  A recent estimate from the Congressional Budget Office (CBO) puts the average credit in the area of $5,000.    With the latest cost estimate for family coverage topping the $20,000 level this year, many will find this a welcome relief.   (How are you doing so far?)

Eligibility will be determined by the difference between the “benchmark plan” and the amount your contribution is expected to be.   Now stay with me on this.   The “benchmark plan” will be the second lowest (or Silver) plan offered through the Exchange.   Your contribution will be calculated between 2% to 9.5% of your annual income depending on where you stand on the FPL scale.

But what will it really cost?

It is hard for industry and non industry citizens to envision what this means because PPACA changes everything so radically that the rates you see today and the rates post-PPACA are a mystery.   When you consider the complete lack of underwriting, an unenforceable mandate* and rating restrictions that limit the ratio in premium between an 18 year old and a 64 year old to 1 to 4……your guess is an good as mine.   As soon as the rates are out they will be subject to change at the next legal opportunity.  The effect of the shift in the demographic of the insured public and the dumping of employer sponsored coverage (directly or indirectly from the 9.5% AGI limit) is yet to be seen.

Employer Concerns

PPACA subjects employers to “shared responsibility” penalities if they don’t offer affordable coverage and this set of regulations suggests there are more penalties to come if the employer contribution toward the cheapest plan offered exceeds 9.5% of the the employee’s AGI.  For employers who might pay into Health Savings Accounts (HSA) for their employees, you may be surprised to note that these regulations do state that the IRS will not include the employer HSA contributions into that calculation when determining if the employees coverage is affordable.  This is because HSA contributions cannot be used to pay for group medical insurance premiums and therefore, cannot reduce the “cost” of the insurance for the employee.

As I read this 87 page document my head is reeling with questions of implementation.  It’s almost like these people have never run a business or spent much time working with employers on the intracacies of providing benefits.   Employers who run any kind of benefits program spend money on many health related items in addition to “Health Insurance Premiums”.  Even employer expenses on Wellness Programs may not necessarily be counted as an employer contribution to the health plan.

What?

If you are asking yourself how in the heck the average Joe is supposed to follow all of this, think about how they get through it now and consider this.

Employee Benefits experts and consultants are going to need an entirely new set of expertise in their portfolio to assist employers in determining where to put their benefit dollars.   The lifespan of the Health Insurance Agent is not only under direct attack from PPACA, but the day of the agent who provides “rates only” as a mode of service is over.   Benefit Professionals like our agency will survive as long as we are welcome in the market and not regulated out of existence.

For the individual purchaser, things may get more impersonal.  Government employed Exchange “agents” are going to spend more time calculating your subsidy than worry too much about advising you what is best for you and your family.

Well, it’s not all bad….you might get $5,000!

Paula L. Wilson, RHU, REBC

*subject to SCOTUS decision due in June, 2012.


Employer’s Getting ready for more PPACA

Employers getting overwhelmed with timelines and deadlines shortly after PPACA was passed are now confused with the slowdown on the action.   Why?  Because timelines change as the administration realizes they keep putting the cart before the horse and extend and amend deadlines.   And so it is with the ominous Summary of Benefit and Coverages requirement.   You know, the one that says people can’t possibly comprehend the benefits as outlined in the current Summary Plan Description, yet need twice the information carved into a 4 page cornucopia of information they still won’t read.   Originally slated for March 2012, employers who were paying attention to these threats of non-compliance are worried about fines and fees…..are they behind the curve?

Well, we are currently receiving  phone calls and inquiries regarding these PPACA regulations  that were to go into effect on 3-23-2012.    Specifically employers are asking us for directions on the required Summary Benefits of Coverage that, if not distributed, can result in $1,000 penalties per failure.  Please note the following:

ON SUMMARY BENEFITS OF COVERAGE 

  • Refresher:  PPACA (Obama Care) requires that ALL employers distribute a very specific 4-Page Summary of Benefits (not to be confused with the current Summary Plan Description).
  • The original deadline for implementation of this requirement has been delayed, in general, to the first renewal after September 23, 2012.   AKA:  All effective or renewal dates beginning 10-1-12.
  • The Insurer is responsible for creating this Summary for each plan offered.   It applies to your health benefits only.  (HSA and HRA information may be included.)
  • It is the responsibility of the employer to make sure this is distributed to all of the employees and their dependents.   It can be in paper or electronic form.   (Caution:  Electronic form must abide by current ERISA rules.  In short, if your employees don’t log on to a computer daily to receive employer communications, that system will not pass. )
  • These rules apply to COBRA beneficiaries as well.  This is where you COBRA administrator will become very important. We are confident that every COBRA administrator we have installed will provide excellent support in this area.
  • A penalty of $1,000 per failure applies to the Employer.
  • This applies to our Self-Funded clients as well.  We will negotiate with the reinsurance carriers for that SBC.
  • There are very specific rules regarding continued distribution of this 4-page SBC as new employees are hired, benefits are change mid-year and upon request of any beneficiary.

ON PREMIUM REBATES

As you know, insurers must rebate excess premiums when they exceed the new MLR (minimum loss ratio) rules.  We have just received details on how employers distribute rebates to employees.   We are reviewing these regulations now regarding the taxability of these to the employees as well as other details.   Since the first rebates are not expected until August 2012, we will be sure to present you with guidance long before they occur.  We believe the taxability will depend on the method of deduction in the first place.   (After tax vs. Pre-Tax via Section 125 Cafeteria POP Plan)

NOTE:  California employers currently receiving rebates from Blue Shield should not confuse these current voluntary rebates with the upcoming MLR rebates.

Ongoing Support during PPACA Implementation

Please be assured that we continue to be very current on all of the implementation details of PPACA and will continue to monitor and assist our employer clients as if PPACA will survive the pending SCOTUS decision.  Our library of details is very complete and we will get information to you on a timely basis.

We appreciate all referrals to your employer group friends and associates that may benefit from our services.   Frankly, I rarely run into insurance “agencies” that know or care much about this challenge.  We continue to be very hands on in order to assure that OUR clients receive the most timely and proper advice as the full implementation of this law approaches.  Planning over the next year is critical.   We are just 19 months away from the full implementation.  HHS is rolling out more and more detail every week.  The sooner we can build relationships with new clients, the better we will be able to guide them through the upcoming tsunami of regulations coming at them.  Please feel free to forward this to your associates.

Paula L. Wilson, RHU, REBC      PAULA@PAULAWILSON.COM     951-694-1009