2014 Fall Health Care Symposium Agenda ACA Whats Happening Now - PowerPoint PPT Presentation

2014 Fall Health Care Symposium

Agenda • ACA – What’s Happening Now • Group up vs. Individu vidual al Coverag erage • Alternative native Fundin nding Options ns • Why Wellnes lness Matters rs • Trans ansforming orming HR HR Through rough Tech chnolog logy

Understanding Obamacare • In order to insure the uninsured, we first have to un- insure the insured. • Next, we require the newly uninsured to be re-insured. • To re-insure the newly uninsured, they are required to pay extra charges to be re-insured. • The extra charges are required so that the original insured, who became uninsured, and then became re- insured, can pay enough extra so that the original uninsured can be insured, which will be free of charge to them.

The ACA Health Care Coverage Landscape - Changes in Effect Prior to 2014 2014 • Loss ss of Medic icare are Part D D retiree ee subs bsidy idy deduction uction • $25 2500 PY cap p on n FSA A salary lary reduct uction ions s (Not otic ice e 201 012-40) 40) • Amendment required by 12/31/2014 • Signif gnific ican ant t Limit mitat atio ions on n HRAs As Annou nnounce nced d in 201 013 • January 2013 FAQ Guidance • Transition (spend down) rule for some pre-existing HRAs • Septemb ptember er 13, 3, 201 013 - Notic ice e 201 013-54 • Curtails stand-alone HRAs, prohibits pre-tax individual policies • Carryo yover ver Guidan idance ce for FSAs As - Notic ice e 201 013-71 71 • Up to $500 • Cannot be combined with FSA grace period changes

The ACA Health Care Coverage Landscape - Changes in Effect 2014 and Beyond • Individu dividual al manda andate e - no o penalt nalty impo posed sed due e to cov over erag age e gap if f indiv dividua idual l enroll rolls s by end d of f open en enroll rollme ment nt (March rch 31, , 2014 014) • Emplo ployer yer play y or pay requirem uiremen ent - NOW W DELAYE LAYED D UNTIL TIL 201 016 for emplo ployer yers s with th less than an 100 00 FTE TE emplo ployees. yees. Wit ith h some me limited “Sledgehammer " " transition nsition relief ief for larger ger emplo ployers ers. • Emplo ployer yer Covera erage ge Report portin ing. g. DELAYED LAYED UNTIL TIL 201 015 (Fin inal al regs March ch 2014) 014) • Required to report minimum essential coverage and premium costs • Applies to insurers and self funded plans

The ACA Health Care Coverage Landscape - Changes in Effect 2014 and Beyond • Exchan changes ges - First open en enrollm rollment nt for indiv dividu idual al covera erage ge comm ommen enced ed October ber 201 013 • October 1 st Exchange Notice Requirement; on-going for new hires • Change hanges Gene nerall ally y Effectiv ective e First st Plan an Year On/ n/After ter Janua nuary ry 1, 201 014 • Emplo ployer yer Quali uality of f Care re Coverage overage Repo portin ing - Dela layed yed pendin nding g guidan idance • Will require information on health care outcome, safety, and wellness • Must make available to enrollees and on internet

Court Decisions of Interest • Ho Hobby Lob obby Decision sion • Religious objections to providing contraceptives • Supreme Court ruled in favor of for-profit employers under Religious Freedom Restoration Act (RFRA) • But state contraceptive equity laws may still apply • Other r challen llenges ges working ng their r way throug ough h the cou ourt rts • Halbig and King - Availability of federal tax subsidies in state run exchanges

Reforms Effective Plan Years On/After 2014 • (ALL) LL) No No pre-ex exis istin ing condit onditio ion exclusio clusions s or limit mitat atio ions are permitted mitted • First wave of reforms applied only to persons under age 19 • (ALL) LL) Prohibit hibitio ion on n excess cessiv ive e wait itin ing g periods iods- i.e. e. no o wait itin ing g perio iod d in excess cess of f 90 days • March 2013 Proposed Regulations substantially retained • Final Regulations issued February 2014 • New 30 day "orientation period" • Eliminates HIPAA Certificates after 12/31/14 • (NGF GF) Fair ir Healt alth h Insu suran ance e Premium miums s (appli licable cable only ly to healt ealth h insurers surers of small all group up plans) ans) • Limitations on premium setting (e.g. limitations on premium setting based on age 3:1. tobacco use 1.5:1, geography) • Final Regulations issued in February 2013

Reforms Effective Plan Years On/After 2014 • (NGF) No discri rimi minat natio ion n based on health th status s is permitt itted ed • Essentially, the same rules that currently exist under HIPAA • The law raises maximum incentive amount for wellness programs that provide the incentive based on achieving a health standard from 20 to 30 percent of the COBRA cost of coverage Also gives the Secretaries of Labor, HHS, and the Treasury leeway to • increase the percentage to 50 percent Final regulations published June 3, 2013 • Some new requirements for standard based wellness plans (activity • only vs. standard based distinction) 50% limited to tobacco cessation • • (All) Coverage rage of dependent t childre ldren n to age 26 - end of of special al rule e for GF plans • Under transition rule, GF plans could exclude adult children if the adult child is eligible to enroll in an eligible employer- sponsored health plan other than a group health plan of a parent This special rule for GF plans does not apply to plan years beginning on or after January 1, 2014

Reforms Effective Plan Years On/After 2014 • (NGF) Cost limi mita tations tions • ALL PLANS - Out-of-pocket expenses do not exceed the amount applicable to coverage related to health savings accounts (HSAs) ($6350 single, $12700 family • 2015 amounts $6600 and $13,200 differs from HSA amounts ($6450,$12900) • ACA compliance does not mean HSA eligible • Small Fully Insured Plans - Deductibles do not exceed $2,000 for single coverage and $4,000 for family coverage (as indexed) • Februa uary ry 2013 3 final al Regulations lations clari rify fy • the deductible requirement only applied to fully insured plans in small group market, but OOP applies to ALL • Transition OOP relief allowed where separate PBM administrator only for the 2014 plan year • Medicare are SGR Fix (Sec 213) • Eliminates deductible (but not OOP) limit • Reopens door for Integrated HRA arrangements coupled with super high deductible coverage

Reforms Effective Plan Years On/After 2014 • (NGF GF) Fully ully insured sured plans ans in small all grou oup market rket must ust provide ide essenti ential al heal ealth h benefi nefits ts (EHB) B) as determi termined ed by referen rence ce to a State te benc nchmark ark plan an • Not applicable to fully insured plans in large group market or self-funded plans • For purposes of applying the prohibition on lifetime and annual limits, large group and self-funded plans may use any single permissible benchmark plan • Final regulations address Minimum Value for pay/play purposes and IRS issues MV calculator • (NGF GF) Grou oup p and d individu dividual al plans ans required uired to cover er routin utine e costs sts of partic icipatio ipation in clini inical cal trials als by quali alifi fied ed individu dividual als • Agency FAQ says good faith compliance standard applies until guidance is issued

Reforms Effective Plan Years On/After 2014 • (NG NGF) F) Addit itio ional al preven ventive ive care re requirem uirements nts fo for PY begin innin ing g on/af n/after er 9/24/1 /24/14 • In accordance with new guidelines Issued by the United States Preventive Services Task Force (USPSTF), non- grandfathered plans will need to cover cancer medication preventive services without charge. The effective date Is based on when the USPSTF added the new requirement. http://www.cms.gov/CCIIO/Resources/Fact-Sheets-and- FAQs/aca.Implementation.faqs18.html