by admin | May 4, 2022 | Compliance
The Departments of Health and Human Services, Labor, and Treasury (the Departments) released Transparency in Coverage (TiC) rules in late 2020 that will require fully insured and self-funded plan sponsors of non-grandfathered group health plans to make important disclosures about in-network and out-of-network rates beginning July 1, 2022. To be ready to meet that deadline, plan sponsors should be coordinating efforts with carriers and third-party administrators (TPAs), as the case may be, to ensure they have the necessary information in the proper format to comply with the new TiC requirements.
Devil in the Details
The TiC rules originally required certain employers to provide “machine readable” files that disclose in-network rates, out-of-network charges and information relating to prescription drug coverage and costs by January 1, 2022. Last year the Departments delayed enforcement of the prescription drug coverage rules indefinitely until they issue additional guidance. However, plan sponsors should be taking steps now to ensure they can publish the required in-network negotiated rates and out-of-network allowed amounts as laid out in the TiC rules by the new July 1 deadline.
The first required file (In-Network Rate File) must show a plan’s negotiated rates for all covered items and services between the plan or carrier and all in-network providers. The second file (Allowed Amount File) will show both the historical payments to, and billed charges from, out-of-network providers. Plan sponsors must be sure this file includes at least 20 historical entries to safeguard individual privacy. The departments have indicated they will provide more specific guidance as to format and content, but so far have not released more details than what we know from the final rules.
Machine-Readable Files
The machine-readable files must include:
• For each option a group medical plan or carrier offers, the identifier for each such option. The identifier is either the insurer Health Insurance Oversight (HIOS) identifier, or if the plan or insurer does not have a HIOS number, the employer identification number (EIN).
• A billing code, which can include a Current Procedural Terminology (CPT) code, Healthcare Common Procedure Coding System (HCPCS) code, Diagnosis-related Group (DRG) code, or a National Drug Code (NDC) or any other common payer identifier. This content element also requires a plain language description for each billing code of each covered item or service.
In-Network Rate File
The In-Network Rate File must show:
• In-network rates for each item or service provided by in-network providers, including any negotiated rates, fee schedule rates used to determine cost-sharing, or derived amounts, whichever rate is applicable to the plan.
• If a rate is percentage-based, include the calculated dollar amount, or the calculated dollar amount for each National Provider Identifier (NPI) identified provider, if rates differ by providers or tiers. Bundled items and services must be identified by relevant code.
Allowed Amount File
The Allowed Amount File must show:
• Unique out-of-network allowed amounts and billed charges with respect to covered items or services, furnished by out-of-network providers during the 90-day period that begins 180 days prior to the publication date of the file.
• The plan or insurer must omit data for a particular item or service and provider when the plan or insurer would be reporting on payment of out-of-network allowed amounts for fewer than 20 different claims for payment under a single plan or coverage. These amounts must also be expressed as dollar amounts and associated with the NPI, Taxpayer Identification Number, and Place of Service Code for each network provider.
What Should You Do?
Plan sponsors will need to update the information in the required files no less frequently than monthly. This will likely require strong coordination with the carrier in an insured plan and with the TPA in a self-funded plan.
The Departments will require the files to be posted to a public website that consumers can use without providing individually identifiable information. The website should be open access and not require passwords, account setup, login credentials or any other barriers to accessing the required information.
The TiC rules recognize that a plan sponsor might not have its own public website on which it will be able to house the required files. But the rules permit plan sponsors to contract with a carrier, TPA or other third party to produce and house the information on a plan’s behalf. However, plans should be aware that they might ultimately remain responsible for any failures.
A carrier will be responsible for any failure if a plan has required it in writing to ensure a plan’s compliance. Self-funded plans can contract to have another entity provide and update required files, too, but the TiC rules do not provide the same level of protection for any failures by a third party in the self-funded context, so plans should be sure to review relevant indemnification provisions in any third-party vendor service agreement.
Many carriers and TPAs have begun reaching out to employer plan sponsors offering to assist in in providing, preparing, updating, and hosting the required files. Employers should be carefully reviewing their service agreements and related contracts to make certain they include specific provisions dealing with all aspects of the required transparency disclosures.
Conclusion
We will continue to monitor the guidance we expect to be coming soon as to certain administrative requirements regarding formatting and hosting of the required forms and provide updates as needed.
© UBA. All rights reserved.
by admin | Apr 28, 2022 | Cybersecurity
Cybersecurity is no longer an emerging risk but a clear and present one for organizations of all sizes, panelists on a panel at Triple-I’s Joint Industry Forum (JIF) said. This is due in large part to the fact that cybercriminals are increasingly thinking and behaving like businesspeople.
“We’ve seen a large increase in ransomware attacks for the sensible economic reason that they are lucrative,” said Milliman managing director Chris Beck. Cybercriminals also are becoming more sophisticated, adapting their techniques to every move insurers, insureds, and regulators make in response to the latest attack trends. “Because this is a lucrative area for cyber bad actors to be in, specialization is happening. The people behind these attacks are becoming better at their jobs.”
As a result, the challenges facing insurers and the customers are increasing and becoming more complex and costly. Cyber insurance purchase rates reflect the growing awareness of this risk, with one global insurance broker finding that the percentage of its clients who purchased this coverage rose from 26 percent in 2016 to 47 percent in 2020, the U.S. Government Accountability Office (GAO) stated in a May 2021 report.
Panel moderator Dale Porfilio, Triple-I’s chief insurance officer, asked whether cyber is even an insurable risk for the private market. Panelist Paul Miskovich, global business leader for the Pango Group, said cyber insurance has been profitable almost every year for most insurers. Most cyber risk has been managed through more controls in underwriting, changes in cybersecurity tools, and modifications in IT maintenance for employees, he said.
By 2026, projections indicate insurers will be writing $28 billion annually in gross written premium for cyber insurance, according to Miskovich. He said he believes all the pieces are in place for insurers to adapt to the challenges presented by cyber and that part of the industry’s evolution will rely on recruiting new talent.
“I think the first step is bringing more young people into the industry who are more facile with technology,” he said. “Where insurance companies can’t move fast enough, we need partnerships with managing general agents, with technology and data analytics, who are going to bring in data and new information.”
“Reinsurers are in the game,” said Catherine Mulligan, Aon’s global head of cyber, stressing that reinsurers have been doing a lot of work to advance their understanding of cyber issues. “The attack vectors have largely remained unchanged over the last few years, and that’s good news because underwriters can pay more attention to those particular exposures and can close that gap in cybersecurity.”
Mulligan said reinsurers are committed to the cyber insurance space and believe it is insurable. “Let’s just keep refining our understanding of the risk,” she said.
When thinking about the future, Milliman’s Beck stressed the importance of understanding the business-driven logic of the cybercriminals.
If, for example, “insurance contracts will not pay if the insured pays the ransom, the logic for the bad actor is, ‘I need to come up with a ransom schema that I’m still making money’,” but the insured can still pay without using the insurance contract.
This could lead to a scenario in which the ransom demands become smaller, but the frequency of attacks increases. Under such circumstances, insurers might have to respond to demand for a new kind of product.
Originally posted on Insurance Information Institute
by admin | Apr 18, 2022 | Human Resources
Today’s offices potentially span five full generations ranging from Generation Z to the Silent Generation. A coworker could just as easily be raised with a smart phone in hand as they could have used a typewriter at their first job. Some see differences between generational colleagues as an annoyance (“kids these days!”) and many rely on generational stereotypes as fact. Truth of that matter is that generational stereotypes have about as many holes in them as a piece of Swiss cheese. Current research questions the validity of generational stereotypes. This series uncovers top generational myths as a strategy to support a diverse and healthy employee population.
Next, we progress to a group whose eldest members reached adulthood in the year 2000: Millennials (also known as Generation Y). This cohort was born between 1981 and 1996. The top three myths of Millennials include:
- They are the laziest generation at work. Millennials have been called the “trophy” generation with the implication that they receive accolades for just showing up. The impression this leaves in the workforce is that they are lacking motivation to go above and beyond, and may be comfortable phoning it in. The data doesn’t support this critical generalization! Most Millennials are inspired by big, hairy goals at work. In fact, 59% of Millennials reported that competition is “what gets them up in the morning.”
- Millennial employees need life instructions on “adulting.” Children of the ‘80s and ‘90s were raised with a teacher, coach, or parent nearby to instruct or help them figure out a solution. For that reason, they often get labeled as incapable. This may lead you to believe that this generation is lacking smarts, and this couldn’t be further from the truth. Close to 40% of adults aged 25 to 37 have a bachelor’s degree, a percentage that overshadows both Baby Boomers and Generation Y at this same point in their life. Millennials are more educated and more technology savvy than prior generations. One sign of their life skills aptitude? Check out their retirement accounts. Dave Ramsey, personal finance guru, summed it up like this: “Even though Millennials have had less 20 years to build their retirement wealth, they are not that far behind many of those who are closest to retirement.” Yes, they may ask a lot of questions, but don’t let this fool you.
- They are job hoppers. They don’t commit to companies. They leave jobs at the drop of a hat. This tune may sound familiar because you have heard it before. A Pew Research study showed that when you freeze data for age, Generations X and Millennials had similar tenures at work. Workers in the first few decades of their career are more open to looking for new opportunities to explore new jobs and learn. The data show that this sentiment is more closely aligned with a stage in life that all generations have experienced. So, let’s give Millennials a break here. Just because they don’t intend to stick around at one company to receive a glass retirement plaque doesn’t mean they have any less value than other generations.
Despite what you may have heard, Millennials are hard workers with the know-how to quickly pick up new knowledge or skills. They value stability just as much, or more, than prior generations.
© UBA. All rights reserved.
by admin | Apr 14, 2022 | Benefit Plan Tips, Tricks and Traps, Hot Topics
Health insurance is essential to protecting your health but the high cost of coverage may leave you feeling sick. Even after employers pick up a substantial amount of the cost, every year Americans spend thousands of dollars on healthcare while costs are continuing to rise. By taking certain steps, you can stretch your healthcare dollars and still receive the care you need to stay healthy.
- Understand How Your Health Plan Works
Review your plan to learn how to maximize your benefits. You need to know what is covered (and what is not!) and what procedures you need to follow to ensure your claims will get paid. Know what your copayment, coinsurance and deductible costs are before your visit.
Most health insurance plans cover more of your costs if you use their preferred or in-network doctors. If you visit an out-of-network doctor or medical facility, you’ll pay more and may end up being responsible for 100% of the bill. Use your insurer’s online tools to search for in-network providers.
- Choose the Right Places to Get Care
Running to the emergency room when you get sick after hours could drain your wallet. All too often, those suffering from minor illnesses or injuries visit the ER when they don’t need to. The ER should be your last resort – consider using more affordable options like telemedicine or an urgent care center instead. You can still get the care you require in off-hours without having to schedule an appointment.
If you need surgery, you may save money by having it done at an ambulatory surgical center (ASC) which is a modern healthcare facility focused on same-day surgical care, including diagnostic and preventive procedures. Typically, these centers charge less than a hospital.
- Use a Health Savings Account (HSA) or Flexible Spending Account (FSA)
Opening a HSA or an FSA is a handy way to save for medical expenses and reduce your taxable income. They are like personal savings accounts but the money in them is used to pay for health care expenses. HSAs are owned by you, earn interest, and can be transferred to a new employer. FSAs are owned by your employer, do not earn interest, and must be used within the calendar year.
- Ask Your Doctor About Remote Patient Monitoring (RPM)
RPM is the use of digital technologies to monitor and analyze medical and other health data from patients and electronically transmit this information to healthcare providers for assessment and, when necessary, recommendations and instructions. This type of monitoring is often used to manage high-risk patients, such as those with acute or chronic health conditions such as those with diabetes, hypertension and heart conditions.
- Use Your Preventive Care Benefits
Many health plans pay the full cost for important preventive care. These regular screenings, exams, and immunizations help detect or prevent diseases and medical problems early when they are easier to treat. Annual check-ups, mammograms (usually after the age of 40), flu shots and colonoscopies (usually 1 every 10 years after the age of 50) are examples of preventive care. These checks can save you a lot of money because they catch problems early.
Health insurance isn’t mandatory – there’s no law requiring you to buy it – but, health insurance is an important part of staying healthy, financially and physically. Since most people who don’t have insurance made that decision based on money instead of what is best for their health, they usually don’t have doctor appointments for the same reason – it’s too expensive. But skipping routine care can end up being more expensive than your premiums, especially if you have serious health issues that aren’t caught early. Think of it like care maintenance: regularly changing your oil might be a hassle but it is essential to prevent a major breakdown down the road.
by admin | Apr 7, 2022 | Hot Topics, Human Resources, Workplace
2021 was quittin’ time in America. Last year alone over 47.4 million Americans quit their jobs. This year, employees seemingly have the upper hand against employers. The Turnover Tsunami, a.k.a. The Great Resignation, has forced a reckoning with the workplace and few employers have come away unscathed. Organizations are now shifting priorities to make employee well-being and retention the priority. The fact of the matter is, after health insurance, the most desirable perks and benefits are those that offer flexibility while improving work/life balance. So, what is it that employees really want to achieve a better work/life balance?
- Hybrid Work – Working remotely some days in the week and at a physical office on others
- Flexibility– Being able to occasionally shift hours that best fit an employee’s life
Why Hybrid Work?
In 2020, people had to change the way they worked overnight and turned their kitchen tables into a fully functioning office. Many employees discovered they were more productive at home. On the other hand, some miss the social nature of the office and working collaboratively in person. Because of these mixed perks of in office vs. working at home, hybrid work can offer the best of both worlds.
According to a survey by the International Workplace Group, 72% of office workers would prefer a hybrid way of working to a full-time return to the office – even if reverting to Monday – Friday routine meant earning more money.
Why Flexible Work?
When the workforce went home because of the COVID-19 pandemic, it caused a change in the expectations of employees and therefore the way companies approach their work environments. The pandemic prompted job seekers to seek flexibility that allows them some level of control of their time. Gene Lanzoni at Guardian said “Time is the most important benefit an employer can provide. For many of us the pandemic afforded us more time, and we’re really not willing to give that back. We had a taste of a more balanced life.”
Balance has never been more important. 60% of families with children have both parents working and for these families, being able to work from home with flexibility is nonnegotiable. Flexibility can allow caregivers to log off from 3 p.m. – 8 p.m. and then come back and do some work after the kids are in bed. When employees have more control of their work schedules, they can free up time to take care of things that pop up in their personal lives – whether it’s running an errand, taking a child to the dentist, or being home for a delivery.
In the end, a flexible schedule contributes to a higher quality of life. Employees don’t have to put their careers on hold to focus on their families or education. This freedom is more valuable in the long run than a paycheck.
Worker retention is more important than ever in 2022. Building a good workplace culture based on the current interests of employees plays a significant role for the success of the company. Businesses now live in an employee-driven job market. It is essential that as an employer you know what benefits your employees value to keep them happy, healthy and working for you.
