United Benefit Advisors Insight and Analysis Blog

Proposed 2016 Benefit and Payment Parameters

Posted by: Linda Rowings    Dec 23, 2014 1:00:00 PM

The Department of Health and Human Services (HHS) has issued its proposed Benefit and Payment Parameters for 2016. While these amounts and dates are not yet final, they may be of help for planning purposes. At this time, HHS expects:

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Topics: Linda Rowings, HHS, 2016, Benefit, Payment, Parameters, UBA PPACA Advisor

Determining Minimum Value and Affordability

Posted by: Linda Rowings    Dec 22, 2014 1:00:00 PM

The IRS has released final regulations that address how wellness incentives or penalties, contributions to a health reimbursement arrangement, and employer contributions to a Section 125 plan are applied to determine affordability. While these regulations were issued in connection with the individual shared responsibility requirement (also called the individual mandate), the agencies said that they expect to use the same approach when determining affordability for purposes of eligibility for the premium tax credit and the employer-shared responsibility/play or pay requirements.

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Topics: Linda Rowings, UBA, PPACA, Section 125, Minimum Value, Affordability

2015 Cost-of-Living Adjustments

Posted by: Linda Rowings    Dec 16, 2014 1:00:00 PM

Many employee benefit limits are automatically adjusted each year for inflation (this is often referred to as an "indexed" limit). The Internal Revenue Service and the Social Security Administration have released a number of indexed figures for 2015.

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Topics: Linda Rowings, IRS, 2015, Cost-of-Living, Adjustments, Social Security Administration

Supreme Court Agrees to Rule on Availability of Premium Tax Credits

Posted by: Linda Rowings    Dec 9, 2014 1:00:00 PM

Premium tax credits are only available to individuals who obtain health coverage through a Marketplace. A dispute has arisen as to whether the IRS has the ability to interpret PPACA to allow the subsidy to individuals who obtain coverage through any Marketplace, or whether the language of PPACA limits eligibility to those who have obtained coverage through a state Marketplace. The U.S. Supreme Court has agreed to rule on whether premium tax credits may only be available to individuals who receive tax subsidies as a result of being enrolled in a state exchange. In the meantime, the IRS has stated that it will continue to issue tax credits to individuals in both state and federally-run Marketplaces.

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Topics: Linda Rowings, PPACA, IRS, Supreme Court, Premium Tax Credits

The “Play or Pay” Package

Posted by: Linda Rowings    Dec 4, 2014 1:50:00 PM

The employer-shared responsibility (“play or pay”) requirements do not apply to small employers and have been delayed until 2016 for most mid-sized employers. This raises the question – what exactly is included in the play or pay requirement, which a small employer may be able to ignore and that mid-size employer may not need to meet until later?

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Topics: Linda Rowings, employers, Play or Pay, mid-sized

Group Health Plans That Do Not Cover Inpatient Hospital or Physician Services

Posted by: Linda Rowings    Nov 25, 2014 1:26:00 PM

Beginning in 2015, large employers must offer affordable, minimum value coverage to their full-time employees or potentially pay a penalty. Some companies have been marketing a plan that they state satisfies the minimum value requirement (an actuarial value of 60%), based upon a calculator provided by the Department of Health and Human Services (HHS), even though the plan does not cover inpatient hospital charges. In Notice 2014-69, HHS and the IRS state that plans that do not provide substantial coverage for physician and inpatient hospital services will not be considered minimum value plans, and that the result obtained through the HHS calculator should not be considered valid since that calculator was built on the assumption that a traditional plan design would be used. The agencies do recognize that some employers have already implemented these plans based on the calculator results, and the Notice states that a limited exception will be available to those employers. To be able to use the exception:

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Topics: Linda Rowings, 2015, In-Patient, Hospital, Physician, Group health plans

Reference-Based Pricing and Cost-Sharing Limits

Posted by: Linda Rowings    Nov 11, 2014 10:19:00 AM

The Department of Labor (DOL), the IRS, and the Department of Health and Human Services (HHS) have jointly issued a FAQ that addresses how "reference-based pricing" works with the Patient Protection and Affordable Care Act's (PPACA) restrictions on out-of-pocket maximums. PPACA limits the out-of-pocket maximum a non-grandfathered plan may impose, and generally requires that co-pays, coinsurance, and deductibles be counted toward this limit. However, premiums, balance billed amounts for non-network providers, and non-covered services do not need to be applied to the out-of-pocket limit. (For 2015, the limits are $6,600 per individual or $13,200 per family.) The new FAQ explains how the out-of-pocket limit applies to plans that use reference-based pricing--i.e., a design under which the plan pays a fixed amount for a particular procedure (such as a knee replacement), which certain providers have agreed to accept as full payment.

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Topics: Linda Rowings, IRS, HHS, DOL, Reference-Based, Pricing, Cost-Sharing, Limits, Department of Labor, Department of Health and Human Services

Requirement to Obtain a Health Plan Identifier (HPID) Delayed

Posted by: Linda Rowings    Nov 6, 2014 8:42:00 AM

On Friday, October 31, 2014, the Department of Health and Human Services (HHS) quietly updated its Health Plan Identifier information page to delay the requirement that insurance carriers and self-funded health plans obtain a health plan identifier (HPID). The delay is in effect until further notice.

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Topics: Linda Rowings, HPID, Health Plan Identifier, delay

Self-Funded Plans Must File Transitional Reinsurance Fee Form by November 15

Posted by: Linda Rowings    Nov 4, 2014 10:29:00 AM

The transitional reinsurance fee (TRF) applies to fully insured and self-funded major medical plans for 2014, 2015, and 2016. The purpose of the fee is to provide funds to help stabilize premiums in the individual insurance market in view of uncertainty about how the Patient Protection and Affordable Care Act (PPACA) would affect claims experience. Insurers are responsible for reporting and paying the fee on the policies they issue, although the fee will generally be passed on to the employer. Plan sponsors of self-funded plans (or their representatives) must report and pay the fee to the federal government at www.pay.gov.

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Topics: Linda Rowings, Self-Funded, PCORI, Patient Centered Outcomes Research Institute, November 15, Transitional Reinsurance Fee

How Wellness Programs Affect Affordability and Minimum Value Calculations

Posted by: Linda Rowings    Oct 24, 2014 10:08:00 AM

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Topics: Linda Rowings, PPACA, wellness programs, FAQs, highlights