Understanding your Letter 226-J
Letter 226-J is the initial letter issued to Applicable Large Employers (ALEs) to notify them that they may be liable for an Employer Shared Responsibility Payment (ESRP). The determination of whether an ALE may be liable for an ESRP and the amount of the proposed ESRP in Letter 226-J are based on information from Forms 1094-C and 1095-C filed by the ALE and the individual income tax returns filed by the ALE’s employees.
What you need to do
- Read your letter and attachments carefully. These documents explain the ESRP process and how the information received affects the computation.
- The letter fully explains the steps to take if you agree or disagree with the proposed ESRP computation.
- Complete the response form (Form 14764) indicating your agreement or disagreement with the letter.
- If you disagree with the proposed ESRP liability, you must provide a full explanation of your disagreement and/or indicate changes needed on Form 14765 (PTC Listing). Return all documents as instructed in the letter by the response date.
- If you agree with the proposed ESRP liability, follow the instructions to sign the response form and return with full payment in the envelope provided.
You may want to
- Review the information reported on Forms 1094-C and 1095-C for the applicable year to confirm that the information filed with the IRS was accurate because the IRS uses that information to compute the ESRP.
- Keep a copy of the letter and any documents you submit.
- Contact us using the information provided in the letter if you have any questions or need additional time to respond.
- Send us a Form 2848 (Power of Attorney and Declaration of Representative) to allow someone to contact us on your behalf. Note that the Form 2848 must state specifically the year and that it is for the Section 4980H Shared Responsibility Payment.
Answers to Common Questions
Why did I receive this letter?
The IRS used the information you provided on Forms 1094/5-C and determined that you are potentially liable for an ESRP.
Where did the IRS get the information used to compute the ESRP?
The IRS used form 1094/5-C filed by the ALE and the individual income tax returns of your full-time employees to identify if they were allowed a premium tax credit.
Is this letter a bill?
No, the letter is the initial proposal of the ESRP
What do I need to do?
Review the letter and attachments carefully and complete the response form by the date provided.
What do I do if the information is wrong or I disagree?
Follow the instructions in the letter to provide corrected information for consideration by the IRS. The IRS will reply with an acknowledgement letter informing you of their final determination.
Do I have appeal rights?
Yes, the acknowledgement letter that you receive will spell out all your rights, including your right to appeal.
General Information
For more info visit ACA information center for Applicable Large Employers
Here’s an excerpt from the 226J letter, and a link to the official sample.
Source:
IRS (9 November 2017). "Understanding your Letter 226-J" [Web blog post]. Retrieved from address https://www.irs.gov/individuals/understanding-your-letter-226-j
IRS to reject returns lacking health coverage disclosure
Where does the IRS stand on ACA (Affordable Care Act)? It's time to know. Check out this article from Benefits Pro for more information.
The Internal Revenue Service has announced that for the first time, tax returns filed electronically in 2018 will be rejected if they do not contain the information about whether the filer has coverage, including whether the filer is exempt from the individual mandate or will pay the tax penalty imposed by the law on those who don’t buy coverage.
Tax returns filed on paper could have processing suspended and thus any possible refund delayed.
The New York Times reports that the IRS appears to be acting in contradiction to the first executive order issued by the Trump White House on inauguration day, in which Trump instructed agencies to “scale back” enforcement of regulations governing the ACA.
The move by the IRS reminds people that they can’t just ignore the ACA, despite the EO. Although only those lacking coverage have to pay the penalty, everyone has to indicate their insurance coverage status on their filing.
According to legal experts cited in the report, the IRS is indicating that although the administration may have leeway in how aggressively it enforces the mandate provision, it’s still in effect unless and until Congress specifically repeals it.
While many people thought they didn’t have to bother with reporting, and many insurers have raised rates anticipating that the lack of a mandate would lead to lower enrollments and higher costs for them, that’s not the case. Initially the IRS did not reject returns because the law was new.
The penalty is pretty steep; for those who don’t have coverage, it can range from $695 for an individual to a maximum of $2,085 for a family or 2.5 percent of AGI, whichever is higher. Not everyone without coverage would be penalized, though; if their income is too low or if the lowest-priced coverage costs more than 8.16 percent of their income, they’ll avoid the penalty.
That said, it’s not known how stringently the IRS will be in enforcing the mandate. But at least taxpayers will know whether they’re exempt from the penalty or whether they’re obligated to buy coverage.
The Effects of Ending the Affordable Care Act’s Cost-Sharing Reduction Payments
Controversy has emerged recently over federal payments to insurers under the Affordable Care Act (ACA) related to cost-sharing reductions for low-income enrollees in the ACA’s marketplaces.
The ACA requires insurers to offer plans with reduced patient cost-sharing (e.g., deductibles and copays) to marketplace enrollees with incomes 100-250% of the poverty level. The reduced cost-sharing is only available in silver-level plans, and the premiums are the same as standard silver plans.
To compensate for the added cost to insurers of the reduced cost-sharing, the federal governments makes payments directly to insurance companies. The Congressional Budget Office (CBO) estimates the cost of these payments at $7 billion in fiscal year 2017, rising to $10 billion in 2018 and $16 billion by 2027.
The U.S. House of Representatives sued the Secretary of the U.S. Department of Health and Human Services under the Obama Administration, challenging the legality of making the cost-sharing reduction (CSR) payments without an explicit appropriation. A district court judge has ruled in favor of the House, but the ruling was appealed by the Secretary and the payments were permitted to continue pending the appeal. The case is currently in abeyance, with status reports required every three months, starting May 22, 2017.
If the CSR payments end – either through a court order or through a unilateral decision by the Trump Administration, assuming the payments are not explicitly authorized in an appropriation by Congress – insurers would face significant revenue shortfalls this year and next.
Many insurers might react to the end of subsidy payments by exiting the ACA marketplaces. If insurers choose to remain in the marketplaces, they would need to raise premiums to offset the loss of the payments.
We have previously estimated that insurers would need to raise silver premiums by about 19% on average to compensate for the loss of CSR payments. Our assumption is that insurers would only increase silver premiums (if allowed to do so by regulators), since those are the only plans where cost-sharing reductions are available. The premium increases would be higher in states that have not expanded Medicaid (and lower in states that have), since there are a large number of marketplace enrollees in those states with incomes 100-138% of poverty who qualify for the largest cost-sharing reductions.
There would be a significant amount of uncertainty for insurers in setting premiums to offset the cost of cost-sharing reductions. For example, they would need to anticipate what share of enrollees in silver plans would be receiving reduced cost-sharing and at what level. Under a worst case scenario – where only people eligible for sharing reductions enrolled in silver plans – the required premium increase would be higher than 19%, and many insurers might request bigger rate hikes.
Figure 1: How much silver premiums would have to rise to compensate for loss of cost-sharing reduction payments
While the federal government would save money by not making CSR payments, it would face increased costs for tax credits that subsidize premiums for marketplace enrollees with incomes 100-400% of the poverty level.
The ACA’s premium tax credits are based on the premium for a benchmark plan in each area: the second-lowest-cost silver plan in the marketplace. The tax credit is calculated as the difference between the premium for that benchmark plan and a premium cap calculated as a percent of the enrollee’s household income (ranging from 2.04% at 100% of the poverty level to 9.69% at 400% of the poverty in 2017).
Any systematic increase in premiums for silver marketplace plans (including the benchmark plan) would increase the size of premium tax credits. The increased tax credits would completely cover the increased premium for subsidized enrollees covered through the benchmark plan and cushion the effect for enrollees signed up for more expensive silver plans. Enrollees who apply their tax credits to other tiers of plans (i.e., bronze, gold, and platinum) would also receive increased premium tax credits even though they do not qualify for reduced cost-sharing and the underlying premiums in their plans might not increase at all.
We estimate that the increased cost to the federal government of higher premium tax credits would actually be 23% more than the savings from eliminating cost-sharing reduction payments. For fiscal year 2018, that would result in a net increase in federal costs of $2.3 billion. Extrapolating to the 10-year budget window (2018-2027) using CBO’s projection of CSR payments, the federal government would end up spending $31 billion more if the payments end.
This assumes that insurers would be willing to stay in the market if CSR payments are eliminated.
Figure 2: How eliminating ACA cost-sharing reduction payments increases federal costs (2018)
Methods
We previously estimated that the increase in silver premiums necessary to offset the elimination of CSR payments would be 19%.
To estimate the average increase in premium tax credits per enrollee, we applied that premium increase to the average premium for the second-lowest-cost silver plan in 2017. The Department of Health and Human Services reports that the average monthly premium for the lowest-cost silver plan in 2017 is $433. Our analysis of premium data shows that the second-lowest-cost silver plan has a premium 4% higher than average than the lowest-cost silver plan.
We applied our estimate of the average premium tax credit increase to the estimated total number of people receiving tax credits in 2017. This is based on the 10.1 million people who selected a plan during open enrollment and qualified for a tax credit, reduced by about 17% to reflect the difference between reported plan selections in 2016 and effectuated enrollment in June of 2016.
We believe the resulting 23% increase in federal costs is an underestimate. To the extent some people not receiving cost-sharing reductions migrate out of silver plans, the required premium increase to offset the loss of CSR payments would be higher. Selective exits by insurers (e.g., among those offering lower cost plans) could also drive benchmark premiums higher. In addition, higher silver premiums would somewhat increase the number of people receiving tax credits because currently some younger/higher-income people with incomes under 400% of the poverty level receive a tax credit of zero because their premium cap is lower than the premium for the second-lowest-cost silver plan. We have not accounted for any of these factors.
Our analysis produces results similar to recent estimates for California by Covered California and a January 2016 analysis from the Urban Institute.
An Early Look at 2018 Premium Changes and Insurer Participation on ACA Exchanges
Each year insurers submit filings to state regulators detailing their plans to participate on the Affordable Care Act marketplaces (also called exchanges). These filings include information on the premiums insurers plan to charge in the coming year and which areas they plan to serve. Each state or the federal government reviews premiums to ensure they are accurate and justifiable before the rate goes into effect, though regulators have varying types of authority and states make varying amounts of information public.
In this analysis, we look at preliminary premiums and insurer participation in the 20 states and the District of Columbia where publicly available rate filings include enough detail to be able to show the premium for a specific enrollee. As in previous years, we focus on the second-lowest cost silver plan in the major city in each state. This plan serves as the benchmark for premium tax credits. Enrollees must also enroll in a silver plan to obtain reduced cost sharing tied to their incomes. About 71% of marketplace enrollees are in silver plans this year.
States are still reviewing premiums and participation, so the data in this report are preliminary and could very well change. Rates and participation are not locked in until late summer or early fall (insurers must sign an annual contract by September 27 in states using Healthcare.gov).
Insurers in this market face new uncertainty in the current political environment and in some cases have factored this into their premium increases for the coming year. Specifically, insurers have been unsure whether the individual mandate (which brings down premiums by compelling healthy people to buy coverage) will be repealed by Congress or to what degree it will be enforced by the Trump Administration. Additionally, insurers in this market do not know whether the Trump Administration will continue to make payments to compensate insurers for cost-sharing reductions (CSRs), which are the subject of a lawsuit, or whether Congress will appropriate these funds. (More on these subsidies can be found here).
The vast majority of insurers included in this analysis cite uncertainty surrounding the individual mandate and/or cost sharing subsidies as a factor in their 2018 rates filings. Some insurers explicitly factor this uncertainty into their initial premium requests, while other companies say if they do not receive more clarity or if cost-sharing payments stop, they plan to either refile with higher premiums or withdraw from the market. We include a table in this analysis highlighting examples of companies that have factored this uncertainty into their initial premium increases and specified the amount by which the uncertainty is increasing rates.
Changes in the Second-Lowest Cost Silver Premium
The second-lowest silver plan is one of the most popular plan choices on the marketplace and is also the benchmark that is used to determine the amount of financial assistance individuals and families receive. The table below shows these premiums for a major city in each state with available data. (Our analyses from 2017, 2016, 2015, and 2014 examined changes in premiums and participation in these states and major cities since the exchange markets opened nearly four years ago.)
Across these 21 major cities, based on preliminary 2018 rate filings, the second-lowest silver premium for a 40-year-old non-smoker will range from $244 in Detroit, MI to $631 in Wilmington, DE, before accounting for the tax credit that most enrollees in this market receive.
Of these major cities, the steepest proposed increases in the unsubsidized second-lowest silver plan are in Wilmington, DE (up 49% from $423 to $631 per month for a 40-year-old non-smoker), Albuquerque, NM (up 34% from $258 to $346), and Richmond, VA (up 33% from $296 to $394). Meanwhile, unsubsidized premiums for the second-lowest silver premiums will decrease in Providence, RI (down -5% from $261 to $248 for a 40-year-old non-smoker) and remain essentially unchanged in Burlington, VT ($492 to $491).
As discussed in more detail below, this year’s preliminary rate requests are subject to much more uncertainty than in past years. An additional factor driving rates this year is the return of the ACA’s health insurance tax, which adds an estimated 2 to 3 percentage points to premiums.
Most enrollees in the marketplaces (84%) receive a tax credit to lower their premium and these enrollees will be protected from premium increases, though they may need to switch plans in order to take full advantage of the tax credit. The premium tax credit caps how much a person or family must spend on the benchmark plan in their area at a certain percentage of their income. For this reason, in 2017, a single adult making $30,000 per year would pay about $207 per month for the second-lowest-silver plan, regardless of the sticker price (unless their unsubsidized premium was less than $207 per month). If this person enrolls in the second lowest-cost silver plan is in 2018 as well, he or she will pay slightly less (the after-tax credit payment for a similar person in 2018 will be $201 per month, or a decrease of 2.9%). Enrollees can use their tax credits in any marketplace plan. So, because tax credits rise with the increase in benchmark premiums, enrollees are cushioned from the effect of premium hikes.
| Table 1: Monthly Silver Premiums and Financial Assistance for a 40 Year Old Non-Smoker Making $30,000 / Year | ||||||||||
| State | Major City | 2nd Lowest Cost Silver Before Tax Credit |
2nd Lowest Cost Silver After Tax Credit |
Amount of Premium Tax Credit | ||||||
| 2017 | 2018 | % Change from 2017 |
2017 | 2018 | % Change from 2017 |
2017 | 2018 | % Change from 2017 |
||
| California* | Los Angeles | $258 | $289 | 12% | $207 | $201 | -3% | $51 | $88 | 71% |
| Colorado | Denver | $313 | $352 | 12% | $207 | $201 | -3% | $106 | $150 | 42% |
| Connecticut | Hartford | $369 | $417 | 13% | $207 | $201 | -3% | $162 | $216 | 33% |
| DC | Washington | $298 | $324 | 9% | $207 | $201 | -3% | $91 | $122 | 35% |
| Delaware | Wilmington | $423 | $631 | 49% | $207 | $201 | -3% | $216 | $430 | 99% |
| Georgia | Atlanta | $286 | $308 | 7% | $207 | $201 | -3% | $79 | $106 | 34% |
| Idaho | Boise | $348 | $442 | 27% | $207 | $201 | -3% | $141 | $241 | 70% |
| Indiana | Indianapolis | $286 | $337 | 18% | $207 | $201 | -3% | $79 | $135 | 72% |
| Maine | Portland | $341 | $397 | 17% | $207 | $201 | -3% | $134 | $196 | 46% |
| Maryland | Baltimore | $313 | $392 | 25% | $207 | $201 | -3% | $106 | $191 | 81% |
| Michigan* | Detroit | $237 | $244 | 3% | $207 | $201 | -3% | $29 | $42 | 44% |
| Minnesota** | Minneapolis | $366 | $383 | 5% | $207 | $201 | -3% | $159 | $181 | 14% |
| New Mexico | Albuquerque | $258 | $346 | 34% | $207 | $201 | -3% | $51 | $144 | 183% |
| New York*** | New York City | $456 | $504 | 10% | $207 | $201 | -3% | $249 | $303 | 21% |
| Oregon | Portland | $312 | $350 | 12% | $207 | $201 | -3% | $105 | $149 | 42% |
| Pennsylvania | Philadelphia | $418 | $515 | 23% | $207 | $201 | -3% | $211 | $313 | 49% |
| Rhode Island | Providence | $261 | $248 | -5% | $207 | $201 | -3% | $54 | $47 | -13% |
| Tennessee | Nashville | $419 | $507 | 21% | $207 | $201 | -3% | $212 | $306 | 44% |
| Vermont | Burlington | $492 | $491 | 0% | $207 | $201 | -3% | $285 | $289 | 2% |
| Virginia | Richmond | $296 | $394 | 33% | $207 | $201 | -3% | $89 | $193 | 117% |
| Washington | Seattle | $238 | $306 | 29% | $207 | $201 | -3% | $31 | $105 | 239% |
| NOTES: *The 2018 premiums for MI and CA reflect the assumption that CSR payments will continue. **The 2018 premium for MN assumes no reinsurance. ***Empire has filed to offer on the individual market in New York in 2018 but has not made its rates public. SOURCE: Kaiser Family Foundation analysis of premium data from Healthcare.gov and insurer rate filings to state regulators. |
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Looking back to 2014, when changes to the individual insurance market under the ACA first took effect, reveals a wide range of premium changes. In many of these cities, average annual premium growth over the 2014-2018 period has been modest, and in two cites (Indianapolis and Providence), benchmark premiums have actually decreased. In other cities, premiums have risen rapidly over the period, though in some cases this rapid growth was because premiums were initially quite low (e.g., in Nashville and Minneapolis).
| Table 2: Monthly Benchmark Silver Premiums for a 40 Year Old Non-Smoker, 2014-2018 |
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| State | Major City | 2014 | 2015 | 2016 | 2017 | 2018 | Average Annual % Change from 2014 to 2018 | Average Annual % Change After Tax Credit, $30K Income |
| California | Los Angeles | $255 | $257 | $245 | $258 | $289 | 3% | -1% |
| Colorado | Denver | $250 | $211 | $278 | $313 | $352 | 9% | -1% |
| Connecticut | Hartford | $328 | $312 | $318 | $369 | $417 | 6% | -1% |
| DC | Washington | $242 | $242 | $244 | $298 | $324 | 8% | -1% |
| Delaware | Wilmington | $289 | $301 | $356 | $423 | $631 | 22% | -1% |
| Georgia | Atlanta | $250 | $255 | $254 | $286 | $308 | 5% | -1% |
| Idaho | Boise | $231 | $210 | $273 | $348 | $442 | 18% | -1% |
| Indiana | Indianapolis | $341 | $329 | $298 | $286 | $337 | 0% | -1% |
| Maine | Portland | $295 | $282 | $288 | $341 | $397 | 8% | -1% |
| Maryland | Baltimore | $228 | $235 | $249 | $313 | $392 | 15% | -1% |
| Michigan* | Detroit | $224 | $230 | $226 | $237 | $244 | 2% | -1% |
| Minnesota** | Minneapolis | $162 | $183 | $235 | $366 | $383 | 24% | 6% |
| New Mexico | Albuquerque | $194 | $171 | $186 | $258 | $346 | 16% | 1% |
| New York*** | New York City | $365 | $372 | $369 | $456 | $504 | 8% | -1% |
| Oregon | Portland | $213 | $213 | $261 | $312 | $350 | 13% | -1% |
| Pennsylvania | Philadelphia | $300 | $268 | $276 | $418 | $515 | 14% | -1% |
| Rhode Island | Providence | $293 | $260 | $263 | $261 | $248 | -4% | -1% |
| Tennessee | Nashville | $188 | $203 | $281 | $419 | $507 | 28% | 2% |
| Vermont | Burlington | $413 | $436 | $468 | $492 | $491 | 4% | -1% |
| Virginia | Richmond | $253 | $260 | $276 | $296 | $394 | 12% | -1% |
| Washington | Seattle | $281 | $254 | $227 | $238 | $306 | 2% | -1% |
| NOTES: *The 2018 premiums for MI and CA reflect the assumption that CSR payments will continue. **The 2018 premium for MN assumes no reinsurance. ***Empire has filed to offer on the individual market in New York in 2018 but has not made its rates public. SOURCE: Kaiser Family Foundation analysis of premium data from Healthcare.gov and insurer rate filings to state regulators. |
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Changes in Insurer Participation
Across these 20 states and DC, an average of 4.6 insurers have indicated they intend to participate in 2018, compared to an average of 5.1 insurers per state in 2017, 6.2 in 2016, 6.7 in 2015, and 5.7 in 2014. In states using Healthcare.gov, insurers have until September 27 to sign final contracts to participate in 2018. Insurers often do not serve an entire state, so the number of choices available to consumers in a particular area will typically be less than these figures.
| Table 3: Total Number of Insurers by State, 2014 – 2018 | |||||
| State | Total Number of Issuers in the Marketplace | ||||
| 2014 | 2015 | 2016 | 2017 | 2018 (Preliminary) | |
| California | 11 | 10 | 12 | 11 | 11 |
| Colorado | 10 | 10 | 8 | 7 | 7 |
| Connecticut | 3 | 4 | 4 | 2 | 2 |
| DC | 3 | 3 | 2 | 2 | 2 |
| Delaware | 2 | 2 | 2 | 2 | 1 (Aetna exiting) |
| Georgia | 5 | 9 | 8 | 5 | 4 (Humana exiting) |
| Idaho | 4 | 5 | 5 | 5 | 4 (Cambia exiting) |
| Indiana | 4 | 8 | 7 | 4 | 2 (Anthem and MDwise exiting) |
| Maine | 2 | 3 | 3 | 3 | 3 |
| Maryland | 4 | 5 | 5 | 3 | 3 (Cigna exiting, Evergreen1 filed to reenter) |
| Michigan | 9 | 13 | 11 | 9 | 8 (Humana exiting) |
| Minnesota | 5 | 4 | 4 | 4 | 4 |
| New Mexico | 4 | 5 | 4 | 4 | 4 |
| New York | 16 | 16 | 15 | 14 | 14 |
| Oregon | 11 | 10 | 10 | 6 | 5 (Atrio exiting) |
| Pennsylvania | 7 | 8 | 7 | 5 | 5 |
| Rhode Island | 2 | 3 | 3 | 2 | 2 |
| Tennessee | 4 | 5 | 4 | 3 | 3 (Humana exiting, Oscar entering) |
| Vermont | 2 | 2 | 2 | 2 | 2 |
| Virginia | 5 | 6 | 7 | 8 | 6 (UnitedHealthcare and Aetna exiting) |
| Washington | 7 | 9 | 8 | 6 | 5 (Community Health Plan of WA exiting) |
| Average (20 states + DC) | 5.7 | 6.7 | 6.2 | 5.1 | 4.6 |
| NOTES: Insurers are grouped by parent company or group affiliation, which we obtained from HHS Medical Loss Ratio public use files and supplemented with additional research. 1The number of preliminary 2018 insurers in Maryland includes Evergreen, which submitted a filing but has been placed in receivership. SOURCE: Kaiser Family Foundation analysis of premium data from Healthcare.gov and insurer rate filings to state regulators. |
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Uncertainty Surrounding ACA Provisions
Insurers in the individual market must submit filings with their premiums and service areas to states and/or the federal government for review well in advance of these rates going into effect. States vary in their deadlines and processes, but generally, insurers were required to submit their initial rate requests in May or June of 2017 for products that go into effect in January 2018. Once insurers set their premiums for 2018 and sign final contacts at the end of September, those premiums are locked in for the entire calendar year and insurers do not have an opportunity to revise their rates or service areas until the following year.
Meanwhile, over the course of this summer, the debate in Congress over repealing and replacing the Affordable Care Act has carried on as insurers set their rates for next year. Both the House and Senate bills included provisions that would have made significant changes to the law effective in 2018 or even retroactively, including repeal of the individual mandate penalty. Additionally, the Trump administration has sent mixed signals over whether it would continue to enforce the individual mandate or make payments to insurers to reimburse them for the cost of providing legally required cost-sharing assistance to low-income enrollees.
Because this policy uncertainty is far outside the norm, insurers are making varying assumptions about how this uncertainty will play out and affect premiums. Some states have attempted to standardize the process by requesting rate submissions under multiple scenarios, while other states appear to have left the decision up to each individual company. There is no standard place in the filings where insurers across all states can explain this type of assumption, and some states do not post complete filings to allow the public to examine which assumptions insurers are making.
In the 20 states and DC with detailed rate filings included in the previous sections of this analysis, the vast majority of insurers cite policy uncertainty in their rate filings. Some insurers make an explicit assumption about the individual mandate not being enforced or cost-sharing subsidies not being paid and specify how much each assumption contributes to the overall rate increase. Other insurers state that if they do not get clarity by the time final rates must be submitted – which has now been delayed to September 5 for the federal marketplace – they may either increase their premiums further or withdraw from the market.
Table 4 highlights examples of insurers that have explicitly factored into their premiums an assumption that either the individual mandate will not be enforced or cost-sharing subsidy payments will not be made and have specified the degree to which that assumption is influencing their initial rate request. As mentioned above, the vast majority of companies in states with detailed rate filings have included some language around the uncertainty, so it is likely that more companies will revise their premiums to reflect uncertainty in the absence of clear answers from Congress or the Administration.
Insurers assuming the individual mandate will not be enforced have factored in to their rate increases an additional 1.2% to 20%. Those assuming cost-sharing subsidy payments will not continue and factoring this into their initial rate requests have applied an additional rate increase ranging from 2% to 23%. Because cost-sharing reductions are only available in silver plans, insurers may seek to raise premiums just in those plans if the payments end. We estimate that silver premiums would have to increase by 19% on average to compensate for the loss of CSR payments, with the amount varying substantially by state.
Several insurers assumed in their initial rate filing that payment of the cost-sharing subsidies would continue, but indicated the degree to which rates would increase if they are discontinued. These insurers are not included in the Table 4. If CSR payments end or there is continued uncertainty, these insurers say they would raise their rates an additional 3% to 10% beyond their initial request – or ranging from 9% to 38% in cases when the rate increases would only apply to silver plans. Some states have instructed insurers to submit two sets of rates to account for the possibility of discontinued cost-sharing subsidies. In California, for example, a surcharge would be added to silver plans on the exchange, increasing proposed rates an additional 12.4% on average across all 11 carriers, ranging from 8% to 27%.
| Table 4: Examples of Preliminary Insurer Assumptions Regarding Individual Mandate Enforcement and Cost-Sharing Reduction (CSR) Payments |
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| State | Insurer | Average Rate Increase Requested | Individual Mandate Assumption | CSR Payments Assumption | Requested Rate Increase Due to Mandate or CSR Uncertainty |
| CT | ConnectiCare | 17.5% | Weakly enforced1 | Not specified | Mandate: 2.4% |
| DE | Highmark BCBSD | 33.6% | Not enforced | Not paid | Mandate and CSR: 12.8% combined impact |
| GA | Alliant Health Plans | 34.5% | Not enforced | Not paid | Mandate: 5.0% CSR: Unspecified |
| ID | Mountain Health CO-OP | 25.0% | Not specified | Not paid | CSR: 17.0% |
| ID | PacificSource Health Plans | 45.6% | Not specified | Not paid | CSR: 23.2% |
| ID | SelectHealth | 45.0% | Not specified | Not paid | CSR: 20.0% |
| MD | CareFirst BlueChoice | 45.6% | Not enforced | Potentially not paid | Mandate: 20.0% |
| ME | Harvard PilgrimHealth Care | 39.7% | Weakly enforced | Potentially not paid | Mandate: 15.9% |
| MI | BCBS of MI | 26.9% | Weakly enforced | Potentially not paid (two rate submissions) | Mandate: 5.0% |
| MI | Blue Care Network of MI | 13.8% | Weakly enforced | Potentially not paid (two rate submissions) | Mandate: 5.0% |
| MI | Molina Healthcare of MI | 19.3% | Weakly enforced | Potentially not paid (two rate submissions) | Mandate: 9.5% |
| NM | CHRISTUS Health Plan | 49.2% | Not enforced | Potentially not paid | Mandate: 9.0%, combined impact of individual mandate non-enforcement and reduced advertising and outreach |
| NM | Molina Healthcare of NM | 21.2% | Weakly enforced | Paid | Mandate: 11.0% |
| NM | New Mexico Health Connections | 32.8% | Not enforced | Potentially not paid | Mandate: 20.0% |
| OR* | BridgeSpan | 17.2% | Weakly enforced | Potentially not paid | Mandate: 11.0% |
| OR* | Moda Health | 13.1% | Not enforced | Potentially not paid | Mandate: 1.2% |
| OR* | Providence Health Plan | 20.7% | Not enforced | Potentially not paid | Mandate: 9.7%, largely due to individual mandate non-enforcement |
| TN | BCBS of TN | 21.4% | Not enforced | Not paid | Mandate: 7.0% CSR: 14.0% |
| TN | Cigna | 42.1% | Weakly enforced | Not paid | CSR: 14.1% |
| TN | Oscar Insurance | NA (New to state) | Not enforced | Not paid | Mandate: 0%, despite non-enforcement CSR: 17.0%, applied only to silver plans |
| VA | CareFirst BlueChoice | 21.5% | Not enforced | Potentially not paid | Mandate: 20.0% |
| VA | CareFirst GHMSI | 54.3% | Not enforced | Potentially not paid | Mandate: 20.0% |
| WA | LifeWise Health Plan of Washington | 21.6% | Weakly enforced | Not paid | Mandate: 5.2% CSR: 2.3% |
| WA | Premera Blue Cross | 27.7% | Weakly enforced | Not paid | Mandate: 4.0% CSR: 3.1% |
| WA | Molina Healthcare of WA | 38.5% | Weakly enforced | Paid | Mandate: 5.4% |
| NOTES: The CSR assumption “Potentially not paid” refers to insurers that filed initial rates assuming CSR payments are made and indicated that uncertainty over CSR funding would change their initial rate requests. In Michigan, insurers were instructed to submit a second set of filings showing rate increases without CSR payments; the rates shown above assume continued CSR payments. *The Oregon Division of Financial Regulation reviewed insurer filings and advised adjustment of the impact of individual mandate uncertainty to between 2.4% and 5.1%. Although rates have since been finalized, the increases shown here are based on initial insurer requests. 1Connecticare assumes a public perception that the mandate will not be enforced. SOURCE: Kaiser Family Foundation analysis of premium data from Healthcare.gov and insurer rate filings to state regulators. |
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Discussion
A number of insurers have requested double-digit premium increases for 2018. Based on initial filings, the change in benchmark silver premiums will likely range from -5% to 49% across these 21 major cities. These rates are still being reviewed by regulators and may change.
In the past, requested premiums have been similar, if not equal to, the rates insurers ultimately charge. This year, because of the uncertainty insurers face over whether the individual mandate will be enforced or cost-sharing subsidy payments will be made, some companies have included an additional rate increase in their initial rate requests, while other companies have said they may revise their premiums late in the process. It is therefore quite possible that the requested rates in this analysis will change between now and open enrollment.
Insurers attempting to price their plans and determine which states and counties they will service next year face a great deal of uncertainty. They must soon sign contracts locking in their premiums for the entire year of 2018, yet Congress or the Administration could make significant changes in the coming months to the law – or its implementation – that could lead to significant losses if companies have not appropriately priced for these changes. Insurers vary in the assumptions they make regarding the individual mandate and cost-sharing subsidies and the degree to which they are factoring this uncertainty into their rate requests.
Because most enrollees on the exchange receive subsidies, they will generally be protected from premium increases. Ultimately, most of the burden of higher premiums on exchanges falls on taxpayers. Middle and upper-middle income people purchasing their own coverage off-exchange, however, are not protected by subsidies and will pay the full premium increase, switch to a lower level plan, or drop their coverage. Although the individual market on average has been stabilizing, the concern remains that another year of steep premium increases could cause healthy people (particularly those buying off-exchange) to drop their coverage, potentially leading to further rate hikes or insurer exits.
Methods
Data were collected from health insurer rate filing submitted to state regulators. These submissions are publicly available for the states we analyzed. Most rate information is available in the form of a SERFF filing (System for Electronic Rate and Form Filing) that includes a base rate and other factors that build up to an individual rate. In states where filings were unavailable, we gathered data from tables released by state insurance departments. Premium data are current as of August 7, 2017; however, filings in most states are still preliminary and will likely change before open enrollment. All premiums in this analysis are at the rating area level, and some plans may not be available in all cities or counties within the rating area. Rating areas are typically groups of neighboring counties, so a major city in the area was chosen for identification purposes.
4 Main Impacts of Yesterday's Executive Order
Yesterday, President Trump used his pen to set his sights on healthcare having completed the signing of an executive order after Congress failed to repeal ObamaCare.
Here’s a quick dig into some of what this order means and who might be impacted from yesterday's signing.
A Focus On Small Businesses
The executive order eases rules on small businesses banding together to buy health insurance, through what are known as association health plans, and lifts limits on short-term health insurance plans, according to an administration source. This includes directing the Department of Labor to "modernize" rules to allow small employers to create association health plans, the source said. Small businesses will be able to band together if they are within the same state, in the same "line of business," or are in the same trade association.
Skinny Plans
The executive order expands the availability of short-term insurance policies, which offer limited benefits meant as a bridge for people between jobs or young adults no longer eligible for their parents’ health plans. This extends the limited three-month rule under the Obama administration to now nearly a year.
Pretax Dollars
This executive order also targets widening employers’ ability to use pretax dollars in “health reimbursement arrangements”, such as HSAs and HRAs, to help workers pay for any medical expenses, not just for health policies that meet ACA rules. This is a complete reversal of the original provisions of the Obama policy.
Research and Get Creative
The executive order additionally seeks to lead a federal study on ways to limit consolidation within the insurance and hospital industries, looking for new and creative ways to increase competition and choice in health care to improve quality and lower cost.
Avoid these 12 Common Open Enrollment Mistakes
Open enrollment season is right around the corner. Check out this great column by Alan Goforth from Benefits Pro and find out the top mistakes employers and HR have made during open enrollment and what you can do to avoid them.
Every employer or human resources professional has made mistakes during open enrollment.
Trying to accommodate the diverse needs of the workforce in a short timeframe against the backdrop of increasing options and often bewildering regulations, can be a challenge even in the best-run companies.
Avoiding mistakes is impossible, but learning from them is not. Although the list may be limitless, here are a dozen of the most common pratfalls during open enrollmentand how to avoid tripping over them.
1. Failing to communicate
"What we've got here… is failure to communicate." – Cool Hand Luke
This mistake likely has topped the list since open enrollment first came into existence, and it will probably continue to do so. That's because enrollment is a complex procedure, and few challenges are greater that making sure employers, employees, brokers and carriers are on the same page.
Employers have both a stick and a carrot to encourage them to communicate as well as possible. The stick is the Affordable Care Act, which requires all employers subject to the Fair Labor Standards Act to communicate with employees about their health-care coverage, regardless of whether they offer benefits.
As a carrot, an Aflac study found that 80 percent of employees agree that a well-communicated benefits package would make them less likely to leave their jobs
2. Neglecting technology
The integration of new technology is arguably the most significant innovation in the enrollment process in recent years.
This is especially important as younger people enter the workforce. Millennials repeatedly express a preference for receiving and analyzing benefits information by computer, phone or other electronic devices.
The challenge is to make the use of technology as seamless as possible, both for employees who are tech-savvy and for those who are not.
Carriers and brokers are making this an emphasis, and employers should lean on them for practical advice.
See the original article Here.
3. Over-reliance on technology
At the other end of the spectrum is the temptation to rely on technology to do things it never was meant to do.
"Technology is so prevalent in the enrollment space today, but watch out for relying on technology as the one thing that will make or break enrollment," says Kathy O'Brien, vice president of voluntary benefits and nation client group services for Unum in Chattanooga, Tennessee. "Technology is great for capturing data, but it won't solve every problem and doesn't change the importance of the other work you need to do."
4. Succumbing to inertia
It can be frustrating to invest substantial time and effort into employee benefit education, only to have most of the staff do nothing.
Yet that is what happens most of the time. Just 36 percent of workers make any changes from the previous enrollment, and 53 percent spend less than one hour making their selections, according to a LIMRA study.
One reason may be that employees don’t feel assured they are making the right decisions.
Only 10 percent felt confident in their enrollment choices when they were done, according to a VSP Vision Care study. One good strategy for overcoming inertia is to attach dollar values to their choices and show where their existing selections may be leaving money on the table.
5. Cutting too many corners
One of the most difficult financial decisions employers make each year is deciding how much money to allocate to employee benefits.
Spending too much goes straight to the bottom line and could result in having to lay off the very employees they are trying to help. Spending too little, however, can hurt employee retention and recruiting.
Voluntary benefits offer a win-win solution. Employees, who pick up the costs, have more options to tailor a program that meets their own needs.
In a recent study of small businesses, 85 percent of workers consider voluntary benefits to be part of a comprehensive benefits package, and 62 percent see a need for voluntary benefits.
6. Not taking a holistic approach
"Holistic" is not just a description of an employee wellness program; it also describes how employers should think about employee benefit packages.
The bread-and-butter benefits of life and health insurance now may include such voluntary options as dental, vision and critical illness. Employers and workers alike need to understand how all of the benefits mesh for each individual.
Businesses also need to think broadly about their approach to enrollment
"Overall, we take a holistic approach to the customer’s enrollment program, from benefits communication to personalized benefits education and counseling, as well as ongoing, dedicated service," says Heather Lozynski, assistant vice president of premier client management for Colonial Life in Columbia, South Carolina. "This allows the employer to then focus on other aspects of their benefits process."
7. Unbalanced benefits mix
Employee benefits have evolved from plain vanilla to 31 (or more) flavors.
As the job market rebounds and competition for talented employees increases, workers will demand more from their employers.
Benefits that were once considered add-ons are now considered mandatory.
Round out the benefits package with an appealing mix of standard features and voluntary options with the objective of attracting, retaining and protecting top-tier employees.
8. Incomplete documentation
Employee satisfaction is a worthy objective — and so is keeping government regulators happy.
The Affordable Care Act requires employers who self-fund employee health care to report information about minimum essential coverage to the IRS, at the risk of penalties.
Even if a company is not required by law to offer compliant coverage to part-time employees, it still is responsible for keeping detailed records of their employment status and hours worked.
As the old saying goes, the job is not over until the paperwork is done.
9. Forgetting the family
The Affordable Care Act has affected the options available to employers, workers and their families.
Many businesses are dropping spousal health insurance coverage or adding surcharges for spouses who have access to employer-provided insurance at their own jobs.
Also, adult children can now remain on their parents' health policies until they are 26.
Clearly communicate company policies regarding family coverage, and try to include affected family members in informational meetings.
Get to know more about employees' families — it will pay dividends long after open enrollment.
10. Limiting enrollment options
Carriers make no secret about their emphasis on electronic benefits education and enrollment.
All things considered, it is simpler and less prone to copying and data-entry errors.
It would be a mistake, however, to believe that the high-tech option is the first choice of every employee.
Be sure to offer the options of old-fashioned paper documents, phone registration and face-to-face meetings. One good compromise is an on-site enrollment kiosk where a real person provides electronic enrollment assistance.
11. Letting benefits go unused
A benefit is beneficial only if the employee uses it. Too many employees will sign up for benefits this fall, forget about them and miss out on the advantages they offer.
Periodically remind employees to review and evaluate their available benefits throughout the year so they can take advantage of ones that work and drop those that do not.
In addition to health and wellness benefits, also make sure they are taking advantage of accrued vacation and personal days.
Besides maximizing the return on their benefit investment, it will periodically remind them that the employer is looking out for their best interests.
12. Prematurely closing the 'OODA' loop
Col. John Boyd of the U.S. Air Force was an ace fighter pilot. He summarized his success with the acronym OODA: Observe, Orient, Decide and Act. Many successful businesses are adopting his approach.
After the stress of open enrollment, it's tempting to breathe a sigh of relief and focus on something else until next fall.
However, the close of enrollment is a critical time to observe by soliciting feedback from employees, brokers and carriers.
What worked this year, and what didn't? What types of communications were most effective? And how can the process be improves in 2017?
"Make sure you know what is working and what is not," said Linda Garcia, vice president for human resources at Rooms to Go, a furniture retailer based just outside Tampa. "We are doing a communications survey right now to find out the best way to reach each of our 7,500 employees. We also conduct quarterly benefits surveys and ask for their actual comments instead of just checking a box."
Source:
Goforth A. (2017 Aug 22). Avoid these 12 common open enrollment mistakes [Web blog post]. Retrieved from address https://www.benefitspro.com/2017/08/22/avoid-these-12-common-open-enrollment-mistakes?ref=hp-in-depth&page_all=1
Self-funding and Voluntary Benefits: The Dynamic Insurance Duo
Did you know that self-funded health insurance and voluntary benefits can be a dream team when used in conjunction with each other? Check out this great article by Steve Horvath and Dan Johnson from Benefits Pro and find out how you can make the most of this dynamic insurance duo.
In an era of health care reform, double-digit rising health care costs, and plenty of “unknowns,” many employers view their benefit plans as a challenging blend of cost containment strategies and employee retention.
But perhaps they need to better understand the value of a little caped crusader named voluntary benefits.
Employers of all sizes share common goals when it comes to their benefits. They seek affordable, and quality benefits for their employees.
Some companies achieve these goals by cutting costs and going with a high-deductible, self-funded approach. While many associate self-funding with larger employers, in the current marketplace, it has become a viable option for companies across the board.
Especially when paired with a voluntary benefits offering supported by one-on-one communication or a call center, employers are able to cut costs and offer additional insurance options tailored to their employees’ needs. But there’s more.
Voluntary enrollments can help employers meet many different challenges, all of which tie back to cost-containment, streamlined processes and employee understanding and engagement. But before we explore solutions, let’s first understand why so many employers are going the self-funded route.
For most large and small employers, the costs of providing health care to employees and their families are significant and rising.
For companies who may be tight on money and are seeing their fully-insured premiums increase every year with little justification, self-funding serves as a great solution to keep their medical expenses down.
Self-funding: An overview
Self-funding allows employers to:
- Control health plan costs with pre-determined claims funding amounts to a medical plan account, without paying the profit margin of the insurance company.
- Protect their plan from catastrophic claims with stop-loss insurance that helps to pay for claims that exceed the amount set by their self-funded plan.
- Pay for medical claims the plan actually incurs, not the margin a fully insured plan underwrites into their premium, while protecting the plan with catastrophic loss coverage when large expenses are incurred. Plans may offer to share favorable savings with their employees through programs like premium holidays. These programs allow employee contributions to be waived for a period of time selected by the employer to reward employees for low utilization and adequate funding of their claims accounts and reserves.
- Take advantage of current and future year plan management guidance.
- Save on plan costs by using predictive analysis for health and wellness offered by the third-party administrator (TPA).
Beyond these advantages,self-funded plans may not be subject to all of the Affordable Care Act regulations as fully-insured plans, which is one of the reasons they provide a solution for controlling costs. Without these requirements, the plans can be tailored much more precisely to meet the needs of a specific employee group.
Boosting value: Advantages of adding voluntary benefits to a self-funded plan
Based on an employer’s specific benefit plan, and what it offers, employers are able to select voluntary benefits that can complement the plan and properly meet employees’ needs without adding extra costs to the plan.
Employees are then able to customize their own, personal benefit options even further based on their unique needs and available voluntary benefits.
This provides employees a myriad of benefits while also allowing them to account for out-of-pocket costs due to high-deductibles or plan changes, as well as provide long-term protection if the product is portable.
Voluntary solutions are about more than the products
Aside from the common falsehood that voluntary benefits are only about adding ‘gap fillers’ to your plan, you may be pleasantly surprised to learn that conducting a voluntary benefits enrollment can actually offer a number of services, solutions, and products, many of which may be currently unfamiliar to you.
Finding, and funding, a ben-admin solution
Some carriers offer the added bonus of helping employers install a benefits administration system in return for conducting a one-on-one or mandatory call center voluntary benefits enrollment.
The right benefits administration systems can help remove manual processes and allow HR to do what they do best—focus on employees and improving employee programs. No more headaches around changing coverage, change files to carriers, changing payroll-deductions or premiums.
Finding the benefits administration system that works best for your situation can make a big difference for your HR team.
Communication and engagement
Many employees are frustrated and scared about how changes to the insurance landscape will impact them. And with a recent survey noting that 95 percent of employees need someone to talk to for benefits information,1 they clearly are seeking ongoing communications and resources.
During the enrollment process, some carriers work with enrollment and communications companies who understand the employees’ benefit plan options and help guide them to the offerings that are best for them and their families.
At the same time, employers can enhance the communication and engagement efforts on other important corporate initiatives. For example, a client of ours increased employee participation in their high-deductible health plan (HDHP) via pre-communication.
Of the 90 percent of employees that went to the enrollment, nearly 70 percent said they were either likely or very likely to select the HDHP. Just a little bit of communication can go a long way toward employee understanding.
Providing education and engagement about both benefits and workplace initiatives increases the effectiveness of these programs and contributes to keeping costs down for employers. The more engagement employers generate, the healthier and better protected the employees.
Prioritizing health and wellness
Employers can also use the enrollment time with employees to remind them to get their annual exams. Many voluntary plans offer a wellness benefit (e.g. $50 or $100) to incentivize the employee and dependents.
The ROI for an employer’s health plan provides value as regular screenings can help detect health issues in the beginning stages so that proper health care management can begin and medical spend can be minimized.
Employers have also seized the opportunity of a benefits enrollment to implement a full-scale wellness program at reduced costs by aligning it with a voluntary benefits enrollment.
An effective wellness program will approach employee health from a whole-person view, recognizing its physical, social, emotional, financial and environmental dimensions. A properly implemented wellness program can ultimately make healthy actions possible for more of an employee population.
A formidable combination
What employers are seeking is simple -- quality benefits and a way to lower costs. With that in mind, offering a self-funded plan with complementary voluntary benefit products and solutions allows employers to take advantage of multiple opportunities while, at the same time, providing more options for their employees.
In today’s constantly changing landscape, self-funded plans paired with voluntary benefits is a formidable combination – a dynamic insurance duo.
See the original article Here.
Source:
Horvath S., Johnson D. (2016 November 23). Self-funding and voluntary benefits: the dynamic insurance duo [Web blog post]. Retrieved from address https://www.benefitspro.com/2016/11/23/self-funding-and-voluntary-benefits-the-dynamic-in?page_all=1
5 tips to make this the best open enrollment ever
Open enrollment season is right around the corner. Did you know that most people find open enrollment season more burdensome than tax season? As employers begin engaging their employees on healthcare offerings, check out these great tips by Kim Buckey from Benefits Pro on how you can make this year the best open enrollment yet.
Learn from last year’s enrollment
Look back on how your company fared during last year’s open enrollment period.
What were the most time-consuming tasks, and how can they be streamlined this year? What were the top questions asked by employees? Did you achieve your enrollment goals?
Hold a meeting with key internal and external stakeholders on the team and review what worked and what didn’t work last year. Knowing where you are, what your challenges are and will be, and where you’re on the right track will enable you to create a meaningful plan for this year.
Start with strategy
Once you know where you are, figure out where you want to be, how you’re going to get there, and how you’ll determine if you’ve achieved your goals. Make sure your strategy includes:
- An assessment of all of your audiences. Remember, you’re not just communicating to employees, you’re reaching out to family members and to managers as well. Keep in mind that not every audience member has the same education level or understanding of even the most basic benefits concepts.
- What’s changing. Are you adding or eliminating plans? Is cost-sharing changing? Is there a new vendor? Having a thorough understanding of what’s changing will help determine what your messaging should be.
- Defining your corporate objectives. Are you looking to increase participation in a particular plan option, or shift a percentage of your population to a new plan offering? Increase participation in a wellness plan? What percentage? Define your objectives and how you plan on measuring success.
- Your overall messages — and any specific messages targeted to your audiences. You may communicate differently to people already in the plan in which you want to increase participation, for example.
- A schedule. People need to hear messages multiple times before they “register.” Make sure you’re communicating regularly — and thoughtfully — in the weeks leading up to, and during, the enrollment period.
- Media. What messages will you deliver in print (newsletters, posters, postcards, enrollment guides)? What should be communicated in person, through managers or one-on-one enrollment support?
Make this year’s enrollment more active
Eighty percent of Americans spend less than an hour researching benefit options, and 90 percent keep the same plan from year to year. Yet for most employees, their circumstances change annually — whether it be the number of their dependents, their overall health and health care usage or their pay.
Active enrollment — where an employee must proactively choose a plan or go without coverage — can be an important step in getting employees more engaged in their benefits.
Active enrollment has benefits for the employer as well — it provides an opportunity to collect key data (such as current dependent information) and to direct employees to the most cost-effective plans for them.
But helping employees choose the “right” plan requires a robust communication plan, combining basic information about plan options, decision-making tools that address the total cost of coverage (both premium and point-of-service costs) and even one-one-one enrollment support.
Many employees don’t have the information they need to make good decisions, and aren’t likely to seek it out on their own — it must be ‘pushed’ to them.
Take demographics into consideration
When engaging employees around their benefits options, consider the wants, needs, and communication preferences of each demographic. Employees just starting their careers are the most underinsured (and generally least informed) group, often seeing student debt rather than health coverage as a more pressing priority.
A Harris/Accolade poll reveals that when results are broken out by age cohort, workers under 30 are having the greatest difficulty finding their way through the healthcare labyrinth.
Only 56 percent say they are comfortable doing so, compared to 76 percent of retirees. They also report more challenges in making the best care decisions, including understanding cost, coordinating care, choosing and understanding benefits, and finding a doctor they can relate to.
Understand the limitations of decision support tools
Decision support tools enable people to take an active role in managing their health care. While they can certainly help, remember that employees must seek them out and use them, and these tools often assume a level of benefits knowledge your employees might not have.
And, these tools recently have come under scrutiny for their ultimate lack of measurable results. To see the return on investment and value, you must also provide education and communications to provide some context for, and drive usage of, these tools.
By applying these five steps along with setting your team up with designated roles, responsibilities, and deadlines, you’re well on your way toward a more seamless, efficient and effective open enrollment period and to saving both your organization and your coworkers time and money.
But remember, benefits communication isn’t “one and done” at enrollment. You’ll need a year-round plan to help employees make good decisions about their care once they’ve chosen their coverage.
See the original article Here.
Source:
Buckey K. (2017 Aug 25). 5 tips to make this the best open enrollment ever [Web blog post]. Retrieved from address https://www.benefitspro.com/2017/08/25/5-tips-to-make-this-the-best-open-enrollment-ever?page_all=1
SELF-INSURED GROUP HEALTH PLANS
Are you looking to switch your company's healthcare plan to a self-funded option? Take a look at this informative column by the Self-Insurance Institute of America and find out everything you need know when researching the best self-funded plan for your company.
Q. What is a self-insured health plan?
A. A self-insured group health plan (or a 'self-funded' plan as it is also called) is one in which the employer assumes the financial risk for providing health care benefits to its employees. In practical terms, self-insured employers pay for each out of pocket claim as they are incurred instead of paying a fixed premium to an insurance carrier, which is known as a fully-insured plan. Typically, a self-insured employer will set up a special trust fund to earmark money (corporate and employee contributions) to pay incurred claims.
Q. How many people receive coverage through self-insured health plans?
A. According to a 2000 report by the Employee Benefit Research Institute (EBRI), approximately 50 million workers and their dependents receive benefits through self-insured group health plans sponsored by their employers. This represents 33% of the 150 million total participants in private employment-based plans nationwide.
Q. Why do employers self fund their health plans?
A. There are several reasons why employers choose the self-insurance option. The following are the most common reasons:
- The employer can customize the plan to meet the specific health care needs of its workforce, as opposed to purchasing a 'one-size-fits-all' insurance policy.
- The employer maintains control over the health plan reserves, enabling maximization of interest income - income that would be otherwise generated by an insurance carrier through the investment of premium dollars.
- The employer does not have to pre-pay for coverage, thereby providing for improved cash flow.
- The employer is not subject to conflicting state health insurance regulations/benefit mandates, as self-insured health plans are regulated under federal law (ERISA).
- The employer is not subject to state health insurance premium taxes, which are generally 2-3 percent of the premium's dollar value.
- The employer is free to contract with the providers or provider network best suited to meet the health care needs of its employees.
Q. Is self-insurance the best option for every employer?
A. No. Since a self-insured employer assumes the risk for paying the health care claim costs for its employees, it must have the financial resources (cash flow) to meet this obligation, which can be unpredictable. Therefore, small employers and other employers with poor cash flow may find that self-insurance is not a viable option. It should be noted, however, that there are companies with as few as 25 employees that do maintain viable self-insured health plans.
Q. Can self-insured employers protect themselves against unpredicted or catastrophic claims?
A. Yes. While the largest employers have sufficient financial reserves to cover virtually any amount of health care costs, most self-insured employers purchase what is known as stop-loss insurance to reimburse them for claims above a specified dollar level. This is an insurance contract between the stop-loss carrier and the employer, and is not deemed to be a health insurance policy covering individual plan participants.
Q. Who administers claims for self-insured group health plans?
A. Self-insured employers can either administer the claims in-house, or subcontract this service to a third party administrator (TPA). TPAs can also help employers set up their self-insured group health plans and coordinate stop-loss insurance coverage, provider network contracts and utilization review services.
Q. What about payroll deductions?
A. Any payments made by employees for their coverage are still handled through the employer' s payroll department. However, instead of being sent to an insurance company for premiums, the contributions are held by the employer until such time as claims become due and payable; or, if being used as reserves, put in a tax-free trust that is controlled by the employer.
Q. With what laws must self-insured group health plans comply?
A. Self-insured group health plans come under all applicable federal laws, including the Employee Retirement Income Security Act (ERISA), Health Insurance Portability and Accountability Act (HIPAA), Consolidated Omnibus Budget Reconciliation Act (COBRA), the Americans with Disabilities Act (ADA), the Pregnancy Discrimination Act, the Age Discrimination in Employment Act, the Civil Rights Act, and various budget reconciliation acts such as Tax Equity and Fiscal Responsibility Act (TEFRA), Deficit Reduction Act (DEFRA), and Economic Recovery Tax Act (ERTA).
See the original article Here.
Source:
Self-Insurance Institute of America (Date). Self-insured group health plans [Web blog post]. Retrieved from address https://www.siia.org/i4a/pages/index.cfm?pageID=4546
The IRS Is Still Enforcing The Individual Mandate, Despite What Many Taxpayers Believe
Did you know that there are many people who still don't believe that they will be hit by tax penalty if they do not have health insurance? Here is an informative article by Timothy Jost from Health Affairs on why everyone should be keeping up with their health insurance in-order to avoid a tax penalty by the IRS.
There has been considerable speculation since President Trump’s Inauguration Day Affordable Care Act Executive Order as to whether the Internal Revenue Service is in fact enforcing the individual and employer mandates. The IRS website has insisted that the mandates are still in force, despite the Executive Order and despite the fact that the IRS decided not to implement for 2016 tax filings a program rejecting “silent returns” that did not indicate compliance with individual mandate requirements.
There is evidence, however, that many taxpayers do not believe it. An April report from the Treasury Inspector General for Taxpayer Services found that as of March 31, a third fewer taxpayers were paying the penalty than had been the case a year earlier. More importantly, insurers seem to believe that the IRS is not enforcing the mandate, or at least that taxpayers do not believe the IRS is enforcing the mandate, and are raising their rates for 2018 to account for the deteriorating of the risk pool that nonenforcement of the mandate will cause.
It is of note, therefore, that Robert Sheen at the ACA Times has identified several letters from the IRS reaffirming that it is still in fact enforcing the individual, and employer, mandates.
One is a letter reportedly sent in April by the IRS General Counsel to Congressman Bill Huizenga (R-MI) in response to an inquiry as to whether the IRS could waive the employer mandate with respect to a particular employer. The IRS replied that there was no provision in the ACA for waiver of the mandate penalty when it applied and that: “The Executive Order does not change the law; the legislative provisions of the ACA are still in force until changed by the Congress, and taxpayers remain required to follow the law and pay what they may owe.”
In a second letter in June, responding to an individual who had written to President Trump, the IRS similarly responded:
The Executive Order does not change the law; the legislative provisions of the ACA are still in force until changed by the Congress, and taxpayers remain required to follow the law, including the requirement to have minimum essential coverage for each month, qualify for a coverage exemption for the month, or make a shared responsibility payment.
Of course, whether taxpayers believe it, and whether insurers believe taxpayers believe it, is another question.
See the original article Here.
Source:
Jost T. (2017 August 21). The IRS is still enforcing the individual mandate, despite what many taxpayers believe [Web blog post]. Retrieved from address https://healthaffairs.org/blog/2017/08/21/the-irs-is-still-enforcing-the-individual-mandate-despite-what-many-taxpayers-believe/