by admin | Apr 26, 2017 | ACA, Benefit Management
A Summary of Benefits and Coverage (SBC) is four page (double-sided) communication required by the federal government. It must contain specific information, in a specific order, and with a minimum size type, about a group health benefit’s coverage and limitations. If an employer providing an SBC is a covered entity under the Section 1557 of the Patient Protection and Affordable Care Act (ACA), additional requirements apply.
On April 6, 2016, the Centers for Medicare and Medicaid Services (CMS), the Department of Labor (DOL), and the Department of the Treasury issued the final 2017 summary of benefits and coverage (SBC) template, group and individual market SBC instructions, uniform glossary of coverage and medical terms, a coverage example calculator, and calculator instructions.
The SBC is to be used by all health plans, including individual, small group, and large group; insured and self-funded; grandfathered, transitional, and ACA compliant. The new SBC must be used for plan years with open enrollment periods beginning after April 1, 2017. It will not be used for marketplace plans for the 2017 coverage year.
For fully insured plans, the insurer is responsible for providing the SBC to the plan administrator (usually this is the employer). The plan administrator and the insurer are both responsible for providing the SBC to participants, although only one of them actually has to do this.
For self-funded plans, the plan administrator is responsible for providing the SBC to participants. Assistance may be available from the plan administrator’s TPA, advisor, etc., but the plan administrator is ultimately responsible. (The plan administrator is generally the employer, not the claims administrator.)
Changes
The template includes a new “important question” that asks “Are there services covered before you meet your deductible?” and requires family plans to disclose whether or not the plan has embedded deductibles or out-of-pocket limits. This is reported in the “Why This Matters” column in relation to the question “what is the overall deductible?” and plans must list “If you have other family members on the policy, they have to meet their own individual deductible until the overall family deductible has been met” or alternatively, “If you have other family members on the policy, the overall family deductible must be met before the plan begins to pay.”
Tiered networks must be disclosed and the question “Will you pay less if you use a network provider?” is now included. The SBC also includes language that warns participants that they could receive out-of-network providers while they are in an in-network facility. The SBC also indicates that a consumer could receive a “balance bill” from an out-of-network provider.
The “explanatory coverage page” was dropped from the template.
The coverage examples provided clarify the “having a baby” example and the “managing type 2 diabetes” example, in addition to providing a third example of “dealing with a simple fracture.” The coverage example must be calculated assuming that a participant does not earn wellness credits or participate in an employer’s wellness program. If the employer has a wellness program that could reduce the employee’s costs, the employer must include the following language: “These numbers assume the patient does not participate in the plan’s wellness program. If you participate in the plan’s wellness program, you may be able to reduce your costs. For more information about the wellness program, please contact: [insert].”
The column for “Limitations, Exceptions, & Other Important Information” must contain core limitations, which include:
- When a service category or a substantial portion of a service category is excluded from coverage (that is, the column should indicate “brand name drugs excluded” in health benefit plans that only cover generic drugs);
- When cost sharing for covered in-network services does not count toward the out-of-pocket limit;
- Limits on the number of visits or on specific dollar amounts payable under the health benefit plan; and
- When prior authorization is required for services.
The template and instructions indicate that qualified health plans (those certified and sold on the Marketplace) that cover excepted abortions (such as those in cases of rape or incest, or when a mother’s life is at stake) and plans that cover non-excepted abortion services must list “abortion” in the covered services box. Plans that exclude abortion must list it in the “excluded services” box, and plans that cover only excepted abortions must list in the “excluded services” box as “abortion (except in cases of rape, incest, or when the life of the mother is endangered).” Health plans that are not qualified health plans are not required to disclose abortion coverage, but they may do so if they wish.
By Danielle Capilla, Originally Published By United Benefits Advisors
by admin | Apr 21, 2017 | ACA, Human Resources
One might describe the series of events leading to the death of the American Health Care Act (Congress’s bill to repeal and replace the Affordable Care Act) as something like a ballistic missile exploding at launch. The Patient Protection and Affordable Care Act (ACA) repeal debate began nearly a decade ago with former President Barack Obama’s first day in office and reemerged as a serious topic during the 2016 presidential election. Even following the retraction of the House bill, repeal of the ACA remains a possibility as the politicians consider alternatives to the recent bill. The possibility of pending legislation has caused some clients to question the need to complete their obligation for ACA reporting on a timely basis this year. The legislative process has produced a great deal of uncertainty which is one thing employers do not like, especially during the busy year end.
While the “repeal and replace” activity is continuing, it is imperative that employers and their brokers put their noses to the grindstone to fulfill all required reporting requirements. To accomplish this, employers will need brokers that can effectively guide them through this tumultuous season. We recommend that employers ask their brokers about their strategies for
- Implementing the employer shared responsibility reporting
- Sending all necessary forms to the employer’s employees
- Submitting the employer’s reporting to the IRS
- Closing out the employer’s 2016 filing season
Employers should also inquire about any additional support that the broker provides. They should provide many of the services that we at Health Cost Manager provide to our clients: They should apprise their clients of the latest legislative updates through regular email communication and informational webinars. Brokers should also bring in experts in the field that have interacted with key stakeholders in Washington. And most important, they should remain available during this uncertain period to answer any questions or concerns from clients.
We know employers would prefer not to have to comply with these reporting obligations – many have directly told us so. We understand this requires additional work on their part to gather information for the reporting and increased compliance responsibility. Knowing how stressful the reporting season can be for employers, brokers should go out of their way to help their clients feel confident that they can steer through the reporting process smoothly. The broker’s role should be to take as much of the burden off the employer’s shoulders as possible to enable them to reach compliance in the most expedient manner possible. Sometimes this involves stepping in to solve data or other technical issues, or answering a compliance-related question that helps the client make important decisions. It’s all part of helping employers navigate through the ACA’s strong headwinds during these uncertain times.
By Michael Weiskirch, Originally Published By United Benefit Advisors
by admin | Apr 19, 2017 | Health & Wellness, Human Resources
I am proud to say that I have been involved in corporate wellness since the mid-1980s. Helping employees live healthier and happier lives, as well as supporting employers with best-in-class tools to improve their cultures, have been my passion and purpose. I have witnessed and worked on corporate wellness since the time when physical health was the most important aspect of workers’ health. I cannot say I have worked with wellness since its inception, though. Corporate wellness has been around longer than many people think. To predict the future of wellness, we must understand its past.
Writings about the effects of work exposure on workers and how to improve workers’ health and well-being can be found as early as the 1700s1. Later, the industrial revolution brought many health issues to workers such as working 14 to 16 hours a day, low wages, and very poor working conditions2. The World Health Organization’s (WHO) definition of health in the 1940s as “a state of complete physical, mental, and social well-being and not merely the absence of disease or infirmity” opened our eyes to the concept of health and wellness as a more complex one3. In addition, the work of Halbert Dunn in 1959 helped the word “wellness” circulate more widely in the public health field, but it was the CBS 60 Minutes program with Dan Rather in 1979 titled, “Wellness, there’s a word you don’t hear every day,” that created curiosity about what corporate wellness was at that time – emphasis on physical health4. Corporate wellness has evolved since then and many studies have been published leading to a wealth of knowledge on best practices, return on investment (ROI), value of investment, risk reduction, health improvement, and more. The March 2017 edition of Health Affairs was dedicated exclusively on the relationship of work and health, and health and work highlighting important recent studies on wellness. Wellness has moved from physical health to thriving in other dimensions such as emotional, financial, spiritual, social, and intellectual health. In addition, many theories on behavior change and behavior economics have been adopted in wellness programs and its incentive designs. Wellness has changed from a “nice to have” to a “must have” benefit, but it must be done right and implemented consistently in order to provide positive results that align with your company’s goals.
I don’t have a crystal ball or special powers, but I believe the future of wellness lies in the following:
- Millennials in the workforce will demand more sophisticated technology.
- The traditional health risk assessment will be replaced by a more holistic kind – check out the True Vitality Test from The Blue Zones. (The UBA Health Plan Survey finds that although 72.5 percent of wellness programs include health risk assessments, their use has been declining, dropping 10.5 percent in three years.)
- Wellness will be part of all successful companies’ business objectives – the Chief Wellness & Well-being Officer’s ultimate goal will be to build a culture of health, self-responsibility, and emotional balance. Wellness will be an important piece of this. For great examples of companies ahead of our time, check out Dr. Ron Goetzel’s work at the Institute of Health and Productivity Studies at John Hopkins School of Public Health.
- Non-traditional workplace environments will replace the health-damaging sitting and sedentary work environment of today.
- Wellness will be more integrated with benefits in general, but more specifically with high-deductible health plans (HDHPs) as a way to help employees fund them.
- ROI will no longer be the focus, and instead it will be part of a long-term business strategy.
- Wellness will have a wider impact overall where employees will thrive in the workplace and bring their health improvement skills to their families and communities.
We now know how to deliver wellness that positively affects cultures and population health. We don’t need any additional studies. All we need are brave and open-minded companies to embark on the journey of optimal wellness and well-being. This journey is full of trials and errors, but also full of self-discovery and growth that can build very profitable companies filled with employees who truly engage at work and thrive every day. Who is with me in this journey?
By Valeria S. Tivnan, Originally Published By United Benefit Advisors
by admin | Apr 14, 2017 | Benefit Management, Group Benefit Plans
Many employers understand the value of having an Employee Assistance Program (EAP) since the heart and soul of organizations are employees. Employees who are physically and mentally healthy, highly productive, engaged in their work, and loyal to their employer contribute positively to their employer’s bottom line. Fortunately, most employees are positive contributors, yet even the best of employees can occasionally have issues or circumstances arise that may inadvertently impact their jobs in a negative way. Having an EAP in place that can address these issues early may mitigate any negative impact to the workplace. This is a win-win for both employees and employers.
A key component of EAP services lies in “catching things early” by assisting employees and helping them address and resolve issues before they impact the workplace. Most employees will use EAP services on a voluntary, self-referred basis that is completely confidential. Some employers may wonder if services are even being used by employees because it won’t be all that apparent, but most EAPs provide a utilization or usage report that will show the number of people served, and possibly the types of reasons services were requested.
If employee issues do begin to appear in the workplace—related to performance, attendance, behavior, or safety—it is important for managers, supervisors, and human resources to also have access to EAP services. They may wish to consult with an employee assistance professional that can provide guidance and direction leading to problem identification and resolution. These issues have the potential to become very costly for the organization—and again, the earlier they can be addressed, the greater chance of success for both employee and employer, with minimal negative impact to the company’s bottom line.
The key to getting the most out of an EAP is to make it easily accessible to employees, safe to use, and visible enough they remember to use it. It is important that employees understand using the EAP is confidential and their identity will not be disclosed to anyone in their organization. Promoting the EAP services with materials such as flyers, posters, or website information with EAP contact information will also increase the likelihood of employees accessing services.
By Nancy Cannon, Originally Published By United Benefit Advisors
by admin | Apr 12, 2017 | Benefit Management, Employee Benefits, Human Resources
With all of the focus that is put into managing and controlling health care costs today, it amazes me how many organizations still look past one of the most effective and least disruptive cost-saving strategies available to employers with 150 or more covered employees – self-funding your dental plan. There is a reason why dental insurers are not quick to suggest making a switch to a self-funded arrangement … it is called profit!
Why self-fund dental?
We know that the notion of self-funding still makes some employers nervous. Don’t be nervous; here are the fundamental reasons why this requires little risk:
- When self-funding dental, your exposure as an employer is limited on any one plan member. Benefit maximums are typically between $1,000 and $2,000 per year.
- Dental claims are what we refer to as high frequency, low severity (meaning many claims, lower dollars per claim), which means that they are far less volatile and much more predictable from year to year.
- You pay for only what you use, an administrative fee paid to the third-party administrator (TPA) and the actual claims that are paid in any given month. That’s it!
Where do you save when you self-fund your dental?
Trend: In our ongoing analysis over the years, dental claims do not trend at anywhere near the rate that the actuaries from any given insurance company project (keep in mind these are very bright people that are paid to make sure that insurance companies are profitable). Therefore, insured rates are typically overstated.
Claims margin: This is money that insurance companies set aside for “claims fluctuation” (i.e., profit). For example, ABC Insurer (we’ll keep this anonymous) does not use paid claims in your renewal projection. They use incurred claims that are always somewhere between three and six percent higher than your actual paid claims. They then apply “trend,” a risk charge and retention to the overstated figures. This factor alone will result in insured rates that are overstated by five to eight percent on insured plans with ABC Insurer, when compared to self-funded ABC Insurer plans.
Risk charges: You do not pay them when you self-fund! This component of an insured rate can be anywhere from three to six percent of the premium.
Reserves: Money that an insurer sets aside for incurred, but unpaid, claim liability. This is an area where insurance companies profit. They overstate the reserves that they build into your premiums and then they earn investment income on the reserves. When you self-fund, you pay only for what you use.
Below is a recent case study
We received a broker of record letter from a growing company headquartered in Massachusetts. They were hovering at about 200 employees enrolled in their fully insured dental plan. After analyzing their historical dental claims experience, we saw an opportunity. After presenting the analysis and educating the employer on the limited amount of risk involved in switching to a self-funded program, the client decided to make the change.
After we had received 12 months of mature claims, we did a look back into the financial impact of the change. Had the client accepted what was historically a well-received “no change” fully insured dental renewal, they would have missed out on more than $90,000 added to their bottom line. Their employee contributions were competitive to begin with, so the employer held employee contributions flat and was able to reap the full financial reward.
This is just one example. I would not suggest that this is the norm, but savings of 10 percent are. If you are a mid-size employer with a fully insured dental plan, self-funding dental is a cost-savings opportunity you and your consultant should be monitoring at every renewal.
By Gary R Goodhile, Originally Published By United Benefit Advisors
