5 ways to prepare for open enrollment during COVID-19
As open enrollment draws near, it's time to critically prepare for it especially during the crazy time that the coronavirus pandemic has brought to many families. Read this blog post to learn more.
The COVID-19 pandemic has focused consumer attention on health care, germs and the impact a single illness can have on their lives, livelihoods and loved ones. With the fall open enrollment season just months away, you have the opportunity to think more critically about the specific plans you choose for yourself and your family, as well as any voluntary benefits that may be available to you, including childcare, elder care and critical illness. In a world where it feels like health is out of the individual’s control, we all want, at the very least, to feel control over our coverage.
As we know all too well, there’s a lot to consider when it comes to choosing and using health care benefits. The most important piece of becoming an informed health care consumer is ensuring you have access to — and understand — the benefits information you need to make smart health care choices. Here are five tips to keep in mind as you prepare for and participate in open enrollment.
1. Prepare for COVID-19 aftermath
As if dealing with the threat of the virus (or actually contracting it) wasn’t enough, consumers must consider the unexpected consequences. Quarantines, stay-at-home orders and business shutdowns have resulted in missed preventive care visits — including annual immunizations. For instance, many children will have missed their preschool vaccinations, which could result in an uptick in measles, mumps and rubella. If school is conducted virtually, the risk of catching one of these highly contagious diseases is somewhat reduced, though consumers should still proceed with caution as states reopen. In fact, with continued waves of COVID-19 expected well into the school season, you and your children may have to wait even longer to get vaccinations due to pent up demand and possible shortages.
Don’t forget that preventive care is covered by most plans at 100% in-network regardless of where that care is received. Schedule your appointments as soon as possible (and permissible in their area), and research other venues for receiving care, such as pharmacies, retail clinics and urgent care facilities. Most are equipped to provide standard vaccinations and/or routine physicals.
Unfortunately, there are also the long-term implications of COVID-19 to consider. Research suggests that there are serious health impacts that emerge in survivors of COVID-19, such as the onset of diabetes and liver, heart and lung problems. And many who were able to ride out the virus at home are finding it’s taking months, not weeks, to fully recover. As a result, you should prepare for the possibility that you, or a loved one, may be ill and possibly out of work for an extended period of time. Be sure to evaluate all of the plans and programs your employer offers to ensure your family has the financial protections you need. For some, a richer health plan with a lower deductible, voluntary plans such as critical illness or hospital indemnity insurance, and buy-up life and disability insurance may be worth investigating for the first time.
2. Re-evaluate postponed elective procedures
Many employees or their family members have postponed or skipped elective procedures — either from fear of exposure to COVID-19 at hospitals and outpatient facilities, or because their hospitals and providers cancelled such procedures to conserve resources to treat COVID-19 patients. As a result, an estimated 28.4 million elective surgeries worldwide could be canceled or postponed in 2020 due to the virus.
As hospitals reopen, it may be difficult to schedule a procedure due to scheduling requirements and pent up demand. A second opinion may be in order if your condition stabilized, improved or worsened during the delay; there may be other treatment options available.
A delay in scheduling also provides an opportunity to “shop around” for a facility that will provide needed care at an appropriate price — especially if you are choosing to go out-of-network or have a plan without a network. Researching cost is the best way to find the most affordable providers and facilities with the best quality, based on your specific needs.
Many medical plans offer second opinion and transparency services, and there are independent organizations who provide “white glove,” personalized support in these areas. Read over your enrollment materials carefully, or check your plan’s summary plan description, to see what your employer offers. If nothing is available, ask your employer to look into it, and don’t hesitate to do some research on your own. Doing so can often result in substantial cost savings, without compromising on quality of care.
3. Confirm your caregivers
Because so few elective procedures were performed during the initial phases of the pandemic, many hospitals sustained huge financial losses. As a result, many small hospitals are closing, and large hospitals are using this opportunity to purchase smaller, independent medical practices that became more financially vulnerable during the pandemic. Further, many physicians have opted to retire or close their practices in light of the drastic reductions to their income during local shutdowns.
Be sure to check up on your preferred health care providers — especially those you might not see regularly — to confirm they are still in business and still in network (if applicable). If you live in a rural area, you may have to travel farther to reach in-network facilities. If you’re currently covered by an HMO or EPO, you may want to evaluate whether that option still makes sense, if your preferred in-network providers are no longer available.
4. Look at ALL the options
Voluntary coverages — such as critical illness, hospital indemnity, buy-up disability, and supplemental life insurance — may help ease your concerns about how you will protect your and your family’s finances if you become ill. Pandemic aside, these benefits can provide a substantial safety net at a relatively low cost. Investigate your employer’s offerings — many employers are offering virtual benefit fairs where vendors can provide more information about these benefits while remaining safe from large social gatherings.
When was the last time you changed your medical plan? If you’ve been keeping the same coverage for years, it might be time to look at what else is available. Your employer may have introduced new plans, or you may find that a different plan makes more sense financially based on how often you need health care. Don’t forget — the cheapest plan isn’t always the one with the lowest premiums.
5. Uncover every resource available
Besides your health coverage (medical, dental and vision), many employers offer other plans and programs to support your health. While you’re already focused on benefits, take the time to learn about what else is available to you. These offerings may range from the previously mentioned advocacy and transparency services and voluntary benefits, to personalized, one-on-one enrollment support, to telemedicine services and an Employee Assistance Program (EAP). Also, many employers made temporary or permanent plan changes to address COVID-19 regulations and concerns. Be sure to familiarize yourself with these changes — and when they might expire.
You may also want to consider setting aside funds in a health savings account or health care flexible spending account (if available). If your employer offers a wellness program, this might be an opportunity to start adopting better health habits to ensure you’re better equipped physically and mentally to deal with whatever lies ahead.
While open enrollment may seem daunting, devoting an hour or two to reviewing your plan options, the programs available to support you and your family physically, mentally and financially, and how to get the most from the coverages you do elect, can go a long way towards providing peace of mind as we face the unknowns of 2021.
SOURCE: Buckey, K. (17 August 2020) "5 ways to prepare for open enrollment during COVID-19" (Web Blog Post). Retrieved from https://www.employeebenefitadviser.com/list/5-ways-to-prepare-for-open-enrollment-during-covid-19
Overview of COVID-19 Law and Guidance for Health and Welfare Plans
The business operations of many small and large companies have been significantly affected due to the coronavirus pandemic. During this time, health and benefit plans are also being affected. Read this blog post to learn more.
The COVID-19 pandemic has significantly affected the business operations of small and large employers alike. To mitigate the harm from the pandemic to employers, the government has enacted major legislation and issued numerous guidance in the past few months pertaining to COVID-19, including rules that address various aspects of employee benefits.
This article provides an overview of significant COVID-19 legislation and guidance related to employer-sponsored health and welfare benefit plans that has been enacted or issued to date.
Some of these changes are mandatory for group health plans. Other are optional. Employers should carefully review these rules to determine any compliance obligations as well as any opportunities to benefit their businesses and respective employees.
Mandated Coverage of COVID-19 Testing (Mandatory)
Effective March 18, 2020 and until the end of the national emergency period for COVID-19, the Families First Coronavirus Response Act (FFCRA) requires group health plans to cover:
- COVID-19 diagnostic testing.
- Certain items and services that result in an order for, or administration of, the testing.
Plans must provide this coverage without imposing any requirements for cost-sharing, prior authorization, or medical management.
CARES ACT
The Coronavirus Aid, Relief, and Economic Security Act (CARES Act), which was signed into law on March 27, 2020, amended the FFCRA's coverage mandate to:
- Expand the scope of COVID-19 diagnostic tests that must be covered.
- Include rules regarding the rate at which a plan must reimburse a health care provider for the mandated services.
- Require coverage of preventive services and vaccines for COVID-19 as of 15 days after such a service or vaccine is given an "A" or "B" rating in a recommendation by the U.S. Centers for Disease Control and Prevention (CDC) or U.S. Preventive Services Task Force.
ADDITIONAL GUIDANCE
On April 11, 2020, the FFCRA and CARES Act FAQs provided additional information about this COVID-19 mandate. Items included details on required coverage of COVID-19 antibody tests, rules regarding required disclosures of the new coverage to plan participants, and which items and services related to COVID-19 testing must be covered by a plan.
Continuation of Health Benefits During Certain Leaves of Absence (Mandatory)
The FFCRA also requires (with some exceptions) employers with fewer than 500 employees to provide certain paid sick leave and family and medical leave related to certain COVID-19 reasons, as follows:
- Paid sick leave. An applicable employer must provide two weeks of emergency paid sick leave (EPSL) to an employee who is unable to work (or telework) due to certain reasons related to COVID-19. Reasons include quarantining of an employee (due to a Federal, state or local order or advice from a health care provider) experiencing COVID-19 symptoms, caring for an individual who is quarantined, and caring for a child under age 18 whose school or child care provider is closed.
- Family and medical leave. The employer must also provide up to twelve weeks of expanded Family Medical and Leave Act (FMLA) leave (ten of which is paid) for an employee who has been employed for at least 30 days and who is unable to work (or telework) due to a bona fide need for leave to care for a child whose school or child care provider is closed or unavailable for reasons related to COVID-19.
During FMLA leave, an employer is required to allow the employee to continue his or her group health coverage at the same premium rate as that of active employees. The DOL has also issued FAQs stating that employers must continue employees' coverage during EPSL, as well. Note, there are also implications for retirement plans under the FFCRA and CARES Act. Although those retirement plan rules are not discussed in this article, some of the CARES Act rules are conceptually similar for retirement plans (e.g., 401(k) plans may allow participants to take "Coronavirus-related" 401(k) plan distributions due to certain COVID-19 reasons).
High-Deductible Health Plans and Health Savings Accounts (Optional)
IRS GUIDANCE
IRS Notice 2020-15 (March 11, 2020), which was issued prior to passage of the FFCRA and CARES Act, provided that a high-deductible health plan (HDHP) will not lose its HDHP status if it covers COVID-19 testing and treatment before the statutory minimum HDHP deductible is met. Therefore, the plan can cover those COVID-19 related services without causing participants to be ineligible to contribute to a health savings account (HSA). IRS Notice 2020-29 (May 12, 2020) clarified that the provisions in Notice 2020-15 apply to an HDHP's reimbursement of expenses incurred on and after January 1, 2020.
CARES ACT
The CARES Act amended the HSA rules to provide that, for plan years before December 31, 2021, an HDHP does not lose its HSA-eligible status if it covers telehealth and other remote healthcare services before the HDHP deductible is met. This CARES Act provision is broader than the IRS Notices, as it provides that an HDHP can cover telehealth services regardless of whether the services are related to COVID-19. The CARES Act also allows participants to use their HSAs, health flexible spending accounts (FSAs), and health reimbursement arrangements (HRAs) to pay for certain over-the-counter drugs without a prescription as well as certain menstrual care products.
Extended Form 5500 Filing Deadline for Certain Plans (Optional)
IRS Notice 2020-23 (April 9, 2020) extended certain deadlines for a plan to file the required annual Form 5500. Under Notice 2020-23, the Form 5500 deadline was extended to July 15, 2020 for any plan whose plan year ended in September, October, or November 2019 (or any plan that was given a filing extension between April 1 and July 15, 2020). Ordinarily, a plan must file its Form 5500 (absent an extension) by the last day of the seventh month following the end of the plan year.
Relief for Certain Disclosures Required by ERISA (Optional)
EBSA Disaster Relief Notice 2020-01, which was issued by the DOL on April 28, 2020, extended the deadlines for plans to provide certain notices and disclosures under Title I of the Employee Retirement Income Security Act of 1974 (ERISA). Under Notice 2020-01, a plan will not be treated as violating ERISA if it fails to timely furnish a notice, disclosure, or document required by Title I of ERISA between March 1, 2020 and 60 days after the announced end of the national emergency declaration for COVID-19. The plan fiduciary, however, must act in good faith to furnish the notice, disclosure, or document as soon as administratively practicable. For this purpose, a plan fiduciary can meet the "good faith" standard by furnishing a document electronically if it reasonably believes that the recipient has access to electronic communication.
Extensions of Certain Plan Deadlines (Mandatory)
A joint notice issued by the DOL and IRS (published May 4, 2020) required group health plans to extend certain timeframes for participants during the "outbreak period" (defined as the period from March 1, 2020 until 60 days after the announced end of the national emergency for COVID-19). Those plans are required to disregard the outbreak period for purposes of determining the following periods and dates:
- The 30-day/60-day special enrollment period under the Health Insurance Portability and Accountability Act (HIPAA).
- The 60-day deadline for a qualified beneficiary to elect continuation coverage under the Consolidated Omnibus Budget Reconciliation Act of 1985 (COBRA).
- The deadlines for a COBRA qualified beneficiary to pay his or her required COBRA premiums.
- The deadline for an individual to notify the plan of COBRA certain qualifying events (e.g., divorce).
- The deadlines for a participant to file benefit claims, appeals, and external review requests with the plan (or to perfect an external review request).
Because of this joint notice, a group health plan must essentially "pause" the above deadlines during the outbreak period. For example, if an individual experienced a COBRA qualifying event on March 1, 2020, the individual would have until 60 days after the end of the outbreak period (rather than 60 days after March 1) to elect COBRA coverage. This is because the joint notice requires a group health plan to pause the 60-day timeframe for COBRA elections during the outbreak period. Also, because the joint notice was issued on May 4 and is retroactive to March 1, plans may be required to re-process previous claim denials that were based on a participant's failure to meet one of the above deadlines between March 1 and May 4.
Cafeteria Plans and Flexible Spending Accounts (Optional)
2020 MIDYEAR ELECTION CHANGES
IRS Notice 2020-29 (May 12, 2020) relaxed the rules regarding cafeteria plan pre-tax elections in light of the COVID-19 pandemic. Under Notice 2020-20, employers may (but are not required to) amend their cafeteria plans to allow participants to make the following mid-year, pre-tax election changes in 2020:
- An election to enroll in the health plan by an eligible employee who previously declined coverage (e.g., someone who waived coverage during open enrollment).
- An election to change plan options (e.g., from an HMO to a PPO) or add dependents.
- An election to drop coverage by a participant.
- An election to enroll in or drop health FSA or dependent care FSA coverage or to increase or decrease health FSA or dependent care FSA contributions.
An employer that wishes to adopt any of all of the above cafeteria plan changes must disclose the changes to employees and amend its cafeteria plan by no later than Dec. 31, 2020 (i.e., an amendment is not required in advance of making the changes).
EXTENDED GRACE PERIOD TO INCUR FSA CLAIMS AND INCREASE OF MAXIMUM HEALTH FSA CARRYOVER AMOUNT
Notice 2020-29 also permits employers to amend their health and dependent care FSAs to allow employees to incur eligible claims through the end of the 2020 calendar year for any FSA plan year (or for any FSA grace period that ends in 2020). For example, if a health FSA has a grace period until March 15, 2020 for a participant to incur eligible claims for the 2019 plan year, the FSA can allow participants to incur expenses through 2020 and use their 2019 elections to pay for those expenses.
This change does not apply to FSAs with a carryover provision. IRS Notice 2020-33 (May 14, 2020), however, provides for a permanent FSA carryover increase based upon annual indexing. For the 2020 plan year, employers may amend a cafeteria plan with carryover provision to allow participants to carry over up to $550 in unused health account balances in the 2021 plan year. An employer that adopts the extended FSA grace periods or the increased carryover limit must amend its cafeteria plan or FSA (as applicable) by no later than December 31, 2021.
Tax-Free Payment of Employees' Student Loans (Optional)
The CARES Act amended Section 127 of the Internal Revenue Code (education assistance programs) to permit employers to pay up to $5,250 of an employee's student loans on a tax-free basis. This provision applies from the date of enactment of the CARES Act (March 27, 2020) through the end of 2020. The payment must be for either the principal or interest of a qualifying education loan incurred by the employee, and the employer can make payment either directly to the lender or as a reimbursement to the employee.
Takeaways for Employers
As employers grapple with the impact of the COVID-19 pandemic and return to normal business operations, it is important for them to be aware of their compliance obligations under the FFCRA, CARES Act and other guidance issued by governmental agencies. Employers should also carefully review the guidance and legislation for potential avenues of benefit for their business and employees.
Additional guidance for both mandatory and optional items is likely forthcoming as well, and COVID-19 continues to have a major impact on both companies and individuals as new infections spike in numerous states. Accordingly, employers would be well-advised to keep a close eye out for new legislation and guidance in the coming months and periodically evaluate their benefits programs for compliance and competitive considerations.
SOURCE Tyler Hall, A.; Schillinger, E. (16 July 2020) "Overview of COVID-19 Law and Guidance for Health and Welfare Plans" (Web Blog Post). Retrieved from https://www.shrm.org/resourcesandtools/hr-topics/benefits/pages/overview-of-covid-19-legislation-and-guidance-for-benefits-plans.aspx
Rising cost of healthcare is hurting HSAs
With HSA's providing a way for users to be able to reduce out-of-pocket costs for healthcare, deductibles still continue to rise. Read this blog post to learn more about why continuously raised healthcare costs are hurting current HSA's and HSA's that could be used for retirement.
Employees are increasingly putting money aside for their HSAs, but they’re using almost the entirety of it to cover basic health needs every year instead of saving the money for future expenses, according to Lively’s 2019 HSA Spend Report.
“People are putting money in and taking money out on a very regular basis, as opposed to trying to create some sort of nest egg for down the road,” says Alex Cyriac, CEO and Co-Founder of Lively.
The San Francisco-based HSA provider says 96% of annual contributions were spent on expected expenses and routine visits as opposed to unexpected health events and retirement care. In 2019, the average HSA account holder spent their savings on doctor visits and services (50%), prescription drug costs (10%), dental care (16%), and vision and eyewear (5%).
The rising cost of healthcare is a factor in these savings trends: Americans spent $11,172 per person on healthcare in 2018, including the rising cost of health insurance, which increased 13.2%, according to National Health Expenditure Accounts. For retirees, the figures are shocking: a healthy 65-year-old couple retiring in 2019 is projected to spend $369,000 in today’s dollars on healthcare over their lifetime, according to consulting firm Milliman.
“Because people can't even afford to save, there's going to be a very low likelihood that most Americans are going to be able to afford their healthcare costs in retirement,” says Shobin Uralil, COO and Co-Founder of Lively.
HSAs were intended to be a way for consumers to save and spend for medical expenses tax-free. Additionally, its biggest benefit comes from being able to use funds saved in an HSA in retirement — when earnings are lowest and healthcare is most expensive. However, just 4% of HSA users had invested assets, according to the Employee Benefit Research Institute.
While HSAs have surged in popularity as a way for more Americans to reduce overall out-of-pocket healthcare spending, more education is required to help account holders understand the benefits of saving and investing their annual contributions for the long-term, the Lively report states.
“As deductibles continue to rise, people just don't seem to have an alternative source for being able to fund those expenses, so they are continuing to dip into their HSA.” Cyriac says. “I think this is just reflective of the broader market trend of healthcare costs continuing to rise, and more and more of those costs being disproportionately passed down to the user.”
SOURCE: Nedlund, E. (29 January 2020) "Rising cost of healthcare is hurting HSAs" (Web Blog Post). Retrieved from https://www.employeebenefitadviser.com/news/rising-cost-of-healthcare-is-hurting-hsas
The Open Enrollment Checklist: Are You Poised for a Successful Season
Are you prepared for open enrollment? According to a recent survey, 56 percent of U.S. adults with employer-sponsored health benefits said health coverage satisfaction is a key factor in deciding whether they should leave their current job. Read this blog post from Employee Benefit News to learn more.
It’s here… the moment we’ve all been waiting for — or, in the case of HR, preparing for (at least we’d hope). That’s right, open enrollment season has arrived.
Open enrollment is a major opportunity for HR to contribute to their company’s performance — both in terms of healthcare savings and employee productivity. The better employees understand their benefits, the more likely they are to make cost-conscious decisions about their plan choices and their healthcare — saving themselves, and their employers, money. Not only that, but a recent survey found that 56% of U.S. adults with employer-sponsored health benefits said that whether or not they like their health coverage is a key factor in deciding to stay at their current job. And, interestingly, satisfaction with benefits and benefits communications have a tremendous impact on job satisfaction and engagement.
Not sure you’ve done everything you could to turn this annual necessity into a true financial, educational game-changer for your organizations? Ask yourself, did you:
Take stock of last year’s enrollment? Before diving into enrollment for 2020, employers should have taken stock of how the company fared last year. Post-mortem meetings with the enrollment team (along with key internal and external stakeholders) to assess what went well (or didn’t) can ensure the coming enrollment season runs smoothly.
In particular, identify the most time-consuming tasks and discuss how they could be streamlined in the future. Second, determine what questions employees asked the most about last year — and be prepared to answer them again this year. Third, consider whether the company achieved its overall open enrollment goals, and what contributed to those results. By addressing the peaks and pitfalls of last year’s season, HR should have a head start on planning for 2020.
Plan your communications strategy?With a defined approach to open enrollment in place, HR at this point should have developed an organized, well-communicated strategy to keep employees informed about their plan options at enrollment and throughout the year. Have you:
· Defined corporate objectives and how to measure success? · Assessed what messages to share with employees, especially anything that is changing — such as adding or eliminating plans or changing vendors? · Determined what information is best delivered in print (e.g. newsletters, posters, postcards, enrollment guides), online or in person through managers or one-on-one enrollment support? Adopting a multi-channel engagement strategy will ensure key messages reach the intended audience(s).
Make sure employees understand the deadline and process for enrolling — and the implications of missing the enrollment window. They must understand whether their existing coverage will roll over, if they’ll default to a specific plan and/or level of coverage (perhaps different from what they currently have), or end up with no coverage at all.
Take a pro-active approach to open enrollment? Ninety percent of employees report that they roll over their same health plan year over year — though this doesn’t indicate overwhelming plan satisfaction. More typically, it’s because they’re intimidated about what they don’t know, are confused about their choices or just don’t care. Employees don’t have the information they need, and aren’t likely to seek it out on their own.
Offering — or even requiring — one-on-one meetings with benefit experts during open enrollment provides a forum for employees to discuss their individual needs and ensure they are selecting the right coverage. These services — often available through brokers or outside engagement firms — provide employees with a safe space to ask specific questions about their health conditions, family history and potential life changes that could affect their insurance needs. This is the ideal time to remind employees that there is no one-size-fits-all plan, and that the least expensive plan on paper may not, ultimately, be the most cost-effective plan over time.
Revisit your SPD? The document we all love to hate, summary plan descriptions (SPDs) remain the best source for information about how each plan works, what it covers and the participant’s rights and responsibilities under that plan.
Having an SPD that is current, appealing (or at least not off-putting) and easy to access can answer many employee questions before they find their way to HR. Simple fixes like adding charts, callout boxes or icons can make your SPDs easier to navigate. Many employers are taking it a step further and offering interactive SPDs, which include robust search functionality and links to definitions, important forms, modeling tools and calculators, vendor sites and even short video clips. By making SPDs digital and interactive, employers can provide employees access to important information about their coverage 24/7 via any device. And, by adding a data analytics component, HR can track which sections employees visit most and pinpoint knowledge gaps about their benefit options to enhance understanding and drive increased benefits usage.
Account for all demographics? With all the focus on today’s multigenerational workforce, it’s important to remember that there’s more to “demographics” than age and gender. Worksite (office vs. shop floor vs. construction site vs. road warrior) can have a tremendous impact on the communications channels you use and when you use them.
And while some “generational generalizations” hold true — many older workers prefer paper, and most young people prefer mobile communication channels — it’s more important to look at employee cohorts from the perspective of differing priorities (planning for retirement vs. retiring student debt), different levels of education and healthcare literacy, and experience with choosing and using benefits. Employees just starting their careers are likely to need more support and different information than a more seasoned worker who’s had years of experience with the enrollment process. Consider the most effective ways to engage the different demographics of your population to gain their attention and interest in choosing the right plan for them.
Equip employees for smart healthcare choices year-round? For most employees, becoming an educated healthcare consumer is a work in progress — which is why many employers offer year-round resources to support smart healthcare choices. That said, these resources are often under-utilized because employees don’t know they exist.
Open enrollment is the perfect time to spread the word about these programs and address the key question for employees: “What’s in it for me?” For example, many employers offer transparency services, which enable employees to research the potential cost of care and compare prices across several providers in their area.
Other resources, such as benefits advocates, can answer questions from employees in real time — including where to get care, how to get a second opinion and what the doctor’s instructions really mean. When used in conjunction, transparency and advocacy services can lower out-of-pocket spending for the employee and reduce costs for the employer. Does your open enrollment communications strategy highlight that these resources exist, outline how they work and explain how they benefit the employee?
What if open enrollment is only a week away and you haven’t taken most, if any, of these steps? It’s not too early to start your to-do list for next year — perhaps by first tackling your SPD and drafting that communications plan. Most importantly, get that post-mortem meeting on the schedule now, while the lessons learned from this year’s open enrollment are still fresh.
SOURCE: Buckey, K. (3 October 2019) "The Open enrollment checklist: Are you Poised for a successful season" (Web Blog Post) https://www.benefitnews.com/list/the-employers-open-enrollment-checklist
Providing an HSA, FSA, or HRA Health Plan for your Employees
When open enrollment hits annually, it is not uncommon for employers to feel exasperated when staring down a list of acronyms such as HSA, FSA and HRA. As it should go without saying, the most common first thought is, “What does any of this mean?” Even the most seasoned experts have difficulty with understanding the complexities of various care options. That’s why in this installment of CenterStage, Kelley Bell, a Group Health Benefits Consultant at Saxon Financial, is here to break down the ‘alphabet soup’ that is HSAs, FSAs and HRAs.
What Is an HSA?
An HSA stands for a Health Savings Account. Kelley stated that HSAs work in conjunction with your existing HDHP plan (given you already have one) to cover costs associated with eligible medical, dental and vision expenses. Available to open just like a bank savings account, Kelley said, “It is your account; yours if you leave the employer and can contribute as long as you have an HDHP and can use the funds until they are gone, even if you are no longer in an HDHP.” For most, this applies to retirement. If you are reasonably healthy throughout your working life, Kelley said you can carry a large HSA balance into retirement. At that point, the funds can be used to cover the out-of-pocket medical costs that often increase with you as you age.
In addition to all the above, certain tax advantages exist within an HSA plan:
- Contributions are excluded from federal income tax.
- Interest earned is tax referable.
- Withdrawals for eligible expenses are exempt from federal income tax.
HSAs are typically available through employers, but individuals can establish one, as well. Many banks offer HSA programs for their customers, meaning if your employer does not offer the benefit, you can create an HSA account there.
What Is an FSA?
An FSA is a Flexible Savings Account. Much like an HSA, these plans cover the payment of medical, dental and vision-related expenses, and contributions you make to the plan are tax-deductible. Similarly, when you open an FSA account, you’re typically provided with a debit card or checkbook, so the funds can be accessed in the account. However, Kelley stated an FSA plan has a catch: “An FSA cannot roll over unused funds from year to year and is not portable.” Therefore, any contributions made to the plan that have not been spent by the end of the year are forfeited.
Some employers, as Kelley noted, do have options that will help you avoid complete forfeiture of unused funds. Certain employers allow their employees to carry over up to $500 of unused funds into the following year, while others will extend the use of the funds for up to two and a half months into the new year. Employers generally will offer one or the other, but never both. Some, however, offer no such option at all.
Kelley mentioned general purpose FSA coverage, and stated it can “make you ineligible for HSA contributions.” She continued to add that certain types will not prevent HSA eligibility, i.e. limited FSA for vision, dental, parking or “post-deductible FSA” which reimburses you for preventative care or for medical expenses that are incurred “after the minimum annual HDHP deductible has been met.” As a result of forfeiting any unused funds in the account, an FSA is best used by someone who has ongoing and predictable medical expenses. In this situation, it is likely you will deplete the funds in the account, whereas if you are considered healthy and have limited medical expenses (i.e. minor illness, sinus infection), the potential for forfeiture is high, and you may have to forgo the account. FSAs are employer-sponsored and typically are an option as part of a ‘cafeteria plan’.
What Is an HRA?
An HRA is a Health Reimbursement Arrangement. Like the other plans described in this article, an HRA is a tax-free employer funded amount of money for healthcare expenses. Contributions, as Kelley explained, “can be excluded from gross income, meaning that won’t pay taxes on that money and reimbursements from the HRA are tax-free when used for qualified medical expenses.” Depending upon the type of HRA, unused funds may or may not be rolled over from one year to the next. However, employers may also allow employees to use their HRA funds even into their retirement.
The benefits of an HRA take action after the employee has met a specific portion (i.e. employee meets 1st $2500 of a $5000 deductible), making it easier for the employee to meet their high deductible. HRAs are good for employers who want more control over how their medical dollars are put to use. Naturally, if the employer is paying the cost of the HRA, it can be of an increased advantage than contributory health insurance premiums and direct payment for out-of-pocket expenses. With an HRA, the employer determines the reimbursements and does not have to contribute the same amount for all employee groups (i.e. tiers of employee coverage, employee/child, employee/spouse and family).
How Saxon Helps
It is important to understand the needs of every client and educate their employees on how to use their healthcare. Saxon values client education and service above all else. We make educating employees a priority and ensure their benefits are understood and easy to use. Saxon represents all of the major carriers, allowing us to secure the best plans and rates for you and your staff, which we review annually.
If you are considering offering an HSA, FSA or HRA insurance plan to your employees, contact Kelley Bell today at (937) 672-1547 or kbell@gosaxon.com to begin exploring the benefits of adding this superior level of coverage today.
Simple Open-Enrollment Tips That Can Make a Big Difference
Many employees associate fear, anxiety or apprehension with open enrollment, the annual period when they select which employer-sponsored benefits they will have the coming year. Read this blog post from SHRM For a few simple tips to help out with this open enrollment season.
Trepidation is what comes to mind for many employees when asked their feelings about open enrollment, the annual period when they select employer-provided benefits for the coming year.
According to a nationally representative sample of 1,000 employees polled earlier this year, 33 percent cited "annoyance" or "dread" as their primary emotions when they thought about open enrollment and just 10 percent of workers said they were "confident" in the benefits choices they made when the enrollment process was over, according to VSP Vision Care's annual Open Talk about Open Enrollment survey.
In another survey, HR software company Namely found that 31 percent of employees give their employer a "C" or lower when it comes to open enrollment.
Here are some tips from benefits experts that will help you raise your grade this open-enrollment season.
What to Do, and Not to Do
Jennifer Benz, national practice leader at benefits communications firm Segal Benz, shared three bad HR practices that undermine open enrollment and three best practices for doing open enrollment the right way.
- Don't hide vital information from employees. Benz recalls how one company sent out its benefits materials but didn't include monthly costs. "A group of enterprising employees crunched the numbers and came up with estimates and circulated a rogue spreadsheet. Dealing with this communications fiasco took more work" than being upfront about costs, she noted.
Best practice: Be transparent and share the reasons you are making benefits changes. Break down the details and do the work for the employees. Provide scenarios so employees can better understand their options and cost breakdowns for different life situations.
- Don't cram in every benefit at once. Some companies hand out pages and pages of text, jamming a year's worth of communications into a few weeks, and figure they have done what they need to do. "What they have done is confused their employees," Benz said.
Best practices: Communicate the technical details of your various benefits over time. "Don't assume employees will weed through all your materials to make sense of the benefits offered to them," Benz said. Also make full use of visual aids. "Photos, icons, infographics, memes, charts, graphics and more—they all help to attract, and more importantly hold, people's attention," noted Amber Riley, a communications consultant to Segal Benz. "Whether you're driving an open-enrollment campaign, creating a new benefits guide or promoting a wellness program, when you increase the visual pleasure of what you are communicating, your people are more likely to engage, learn, understand and ultimately take action."
- Don't give employees too little time to process their open-enrollment choices. While many people wait until the last day to fill out the health care selection forms, they may have been considering their options with family members for weeks, so giving them just a few days to make decisions is not going to be enough.
Best practice: Build in a time frame that gives HR staff and employees the time they need. Benz recommended three weeks.
"People are always talking about learning from the best practices and success stories, but you can also learn a lot from other companies' mistakes," she noted. "When you prepare for enrollment in advance and anticipate issues—including those you and others have experienced in the past—you are better-equipped to avoid missteps. Your employees will notice and appreciate the extra effort."
Help Employees Ace Open Enrollment
"Open enrollment is often time-consuming and confusing for employees, but these choices can make a huge financial impact," said Julie Stich, CEBS, vice president of content at the International Foundation of Employee Benefit Plans, an association of benefit plan sponsors. She suggested that HR share the following advice with employees to help prepare them for the upcoming enrollment season:
- Take your time. Take time to really read through the enrollment materials you receive. If you are invited to a face-to-face meeting, make time to attend. It's possible you'll be offered different plan options and coverages this year. The better you understand the changes, the better decisions you'll make.
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Take a trip down memory lane. Think back to what happened in your life this year. How often did you and your family members need medical services? What kind? Are any treatments ongoing? Think about any life changes that could affect the benefits you need, like a marriage or divorce, a child going off to college, or a spouse changing jobs.
- Look ahead. Consider what the next year will look like for you and your family. Are you planning to have a baby? Knee replacement surgery? A root canal? Does someone need braces? New glasses? Keep this in mind as you look at your coverage options.
- Dive into the details. It's important to note whether the plans' provider networks have changed. Make sure your doctors are still in-network. Is your chiropractor also covered? Does the plan cover orthodontics? Is your spouse's daily prescription drug covered, and did the coverage change? Also consider areas of need like access to specialists, mental health care, therapies, complementary and alternative medicine, and chronic care. Look at the options offered in all plans, including health, dental, vision and disability.
- Get out your calculator. Add up the amount you'll need to pay toward your health premium plus deductibles, co-payments (flat-dollar amounts) for prescriptions and doctor office visits, and co-insurance (a percentage of the cost you'll pay) for services. Understand what you'll be asked to pay if you seek care outside your network. This will give you a clearer picture of how much you're likely to spend. The plan that looks to be the cheapest option may not really be the cheapest for you.
- Determine what's right for you. Consider your comfort level with risk. If you want your family to be covered for every eventuality, a more traditional plan, if one is offered, might be right for you. If you're comfortable taking on some upfront costs, a high-deductible plan with a lower premium ight be your plan of choice.
- Take advantage of extras. Your employer may offer the option to reduce your health premiums in exchange for your participation in a wellness program or health-risk assessment. It may match some or all of the money you save in your 401(k) plan. It might let you set aside tax-deferred money into a health savings account or flexible spending account. Also, check with your employer to see if it offers voluntary insurance with a group discount and payroll deduction for premiums—like critical-illness, pet, auto and homeowners coverage. If these options work for your situation, sign up.
- Ask questions. Don't be shy about asking your HR or benefits department to explain something if you're not sure. They're there to help and want you to make the best decisions for your situation.
"Taking the time upfront to carefully choose the best options will help employees better manage their finances throughout the year, alleviating stress and promoting productivity," Stich said.
SOURCE: Miller, S. (24 September 2019) "Simple Open-Enrollment Tips That Can Make a Big Difference" (Web Blog Post). Retrieved from https://www.shrm.org/ResourcesAndTools/hr-topics/benefits/Pages/simple-open-enrollment-tips-make-a-big-difference.aspx
‘Eye’ spy a savings opportunity for health and vision benefits
The National Eye Institute reported that 61 million adults are at high risk for serious vision loss. Conventionally, vision benefits were offered as an elective, with coverage is focusing on vision tests or discounts for corrective eyewear. Read the following blog post to learn more about vision benefits.
Sixty-one million adults are at high risk for serious vision loss, according to the National Eye Institute, but most U.S. employers don’t include eye care as part of their benefits package. Vision benefits have traditionally been offered as an elective, where coverage is focused on vision tests or discounts for corrective eyewear.
This often results in inadequate coverage for employees and dependents, which can result in unrecognized and untreated issues that impact employee health and productivity, as well as an employer’s bottom line.
Comprehensive eye exams are recommended for adults under the age of 65 at least every two years, according to the American Optometric Association (AOA). These exams are the only way a doctor can detect signs and symptoms of serious conditions without cutting into or scanning body parts.
The total economic burden of eye disorders and vision loss in the U.S. was $139 billion in 2013, which includes $65 billion in direct medical costs strictly due to eye disorders and low vision. Loss of vision among workers results in $48 billion in lost productivity per year.
When it comes to benefit management priorities employers often focus more on chronic condition management. Yet, eye health is often linked to common chronic conditions including diabetes and hypertension. Without early detection of eye and vision health issues, employees cannot properly manage these conditions. Delaying medical treatment can lead to increased absenteeism and reduced productivity, eventually resulting in treatment that comes too late, and at a much higher price tag for employers, employees and family members.
About 68% of Americans with diabetes have been diagnosed with eye complications, many of which could have been prevented through a comprehensive eye exam. Diabetes is the leading cause of blindness among adults, according to the National Institutes of Health. Its prevalence is increasing as one in 10 people worldwide may be affected by 2040, according to research from the International Diabetes Federation.
Nearly half of Americans don’t know that diabetic eye diseases have visible symptoms, according to a 2018 AOA survey. More than one-third of respondents didn’t know a comprehensive eye exam is the only way to determine if a person’s diabetes will cause blindness. These exams, considered the gold standard in clinical vision care, should be covered under the employees’ medical benefits.
Three years ago the Midwest Business Group on Health began a collaboration with the AOA to better understand how employers think about and implement eye health and vision benefits. As part of this partnership, a no-cost eye care benefits toolkit was developed to support employers in evaluating their current eye health and vision care benefits to:
- Understand the importance of early detection so that employees can effectively manage chronic and more serious conditions
- Recognize how to integrate primary and preventive eye care into an overall medical benefit design
- Educate employees on the importance of periodic eye examinations
It’s important that employers better understand the impact of vision care benefits, including lower costs, better employee health, improved job satisfaction, better employee quality of life, and work productivity.
SOURCE: Larson, C. (20 September 2019) "‘Eye’ spy a savings opportunity for health and vision benefits" (Web Blog Post). Retrieved from https://www.benefitnews.com/opinion/vision-loss-resulting-in-billions-in-lost-productivity
Health insurance surpass $20,000 per year, hitting a record
According to an annual survey of employers, the cost of family health coverage has now surpassed $20,000, a record high. The survey also revealed that while most employers pay most of the costs of coverage, workers' average contribution for a family plan is now $6,000. Read this blog post from Employee Benefit News to learn more.
The cost of family health coverage in the U.S. now tops $20,000, an annual survey of employers found, a record high that has pushed an increasing number of American workers into plans that cover less or cost more, or force them out of the insurance market entirely.
“It’s as much as buying a basic economy car,” said Drew Altman, chief executive officer of the Kaiser Family Foundation, “but buying it every year.” The nonprofit health research group conducts the yearly survey of coverage that people get through work, the main source of insurance in the U.S. for people under age 65.
While employers pay most of the costs of coverage, according to the survey, workers’ average contribution is now $6,000 for a family plan. That’s just their share of upfront premiums, and doesn’t include co-payments, deductibles and other forms of cost-sharing once they need care.
The seemingly inexorable rise of costs has led to deep frustration with U.S. healthcare, prompting questions about whether a system where coverage is tied to a job can survive. As premiums and deductibles have increased in the last two decades, the percentage of workers covered has slipped as employers dropped coverage and some workers chose not to enroll. Fewer Americans under 65 had employer coverage in 2017 than in 1999, according to a separate Kaiser Family Foundation analysis of federal data. That’s despite the fact that the U.S. economy employed 17 million more people in 2017 than in 1999.
“What we’ve been seeing is a slow, slow kind of drip-drip erosion in employer coverage,” Altman said.
Employees’ costs for healthcare are rising more quickly than wages or overall economy-wide prices, and the working poor have been particularly hard-hit. In firms where more than 35% of employees earn less than $25,000 a year, workers would have to contribute more than $7,000 for a family health plan. It’s an expense that Altman calls “just flat-out not affordable.” Only one-third of employees at such firms are on their employer’s health plans, compared with 63% at higher-wage firms, according to the Kaiser Family Foundation’s data.
The survey is based on responses from more than 2,000 randomly selected employers with at least three workers, including private firms and non-federal public employers.
Deductibles are rising even faster than premiums, meaning that patients are on the hook for more of their medical costs upfront. For a single person, the average deductible in 2019 was $1,396, up from $533 in 2009. A typical household with employer health coverage spends about $800 a year in out-of-pocket costs, not counting premiums, according to research from the Commonwealth Fund. At the high end of the range, those costs can top $5,000 a year.
While raising deductibles can moderate premiums, it also increases costs for people with an illness or who gets hurt. “Cost-sharing is a tax on the sick,” said Mark Fendrick, director of the Center for Value-Based Insurance Design at the University of Michigan.
Under the Affordable Care Act, insurance plans must cover certain preventive services such as immunizations and annual wellness visits without patient cost-sharing. But patients still have to pay out-of-pocket for other essential care, such as medication for chronic conditions like diabetes or high blood pressure, until they meet their deductibles.
Many Americans aren’t prepared for the risks that deductibles transfer to patients. Almost 40% of adults can’t pay an unexpected $400 expense without borrowing or selling an asset, according to a Federal Reserve survey from May.
That’s a problem, Fendrick said. “My patient should not have to have a bake sale to afford her insulin,” he said.
After years of pushing healthcare costs onto workers, some employers are pressing pause. Delta Air Lines Inc. recently froze employees’ contributions to premiums for two years, Chief Executive Officer Ed Bastian said in an interview at Bloomberg’s headquarters in New York last week.
“We said we’re not going to raise them. We're going to absorb the cost because we need to make certain people know that their benefits structure is real important,” Bastian said. He said the company’s healthcare costs are growing by double-digits. The Atlanta-based company has more than 80,000 employees around the globe.
Some large employers have reversed course on asking workers to take on more costs, according to a separate survey from the National Business Group on Health. In 2020, fewer companies will limit employees to so-called “consumer-directed health plans,” which pair high-deductible coverage with savings accounts for medical spending funded by workers and employers, according to the survey. That will be the only plan available at 25% of large employers in the survey, down from 39% in 2018.
Employers have to balance their desire to control costs with their need to attract and keep workers, said Kaiser’s Altman. That leaves them less inclined to make aggressive moves to tackle underlying medical costs, such as by cutting high-cost hospitals out of their networks. In recent years employers’ healthcare costs have remained steady as a share of their total compensation expenses.
“There’s a lot of gnashing of teeth,” Altman said, “but if you look at what they do, not what they say, it’s reasonably vanilla.”
SOURCE: Tozzi, J. (25 September 2019) "Health insurance surpass $20,000 per year, hitting a record" (Web Blog Post). Retrieved from https://www.benefitnews.com/articles/health-insurance-costs-surpass-20-000-per-year
6 voluntary benefits your employees want
Multigenerational workforces are no longer finding the run-of-the-mill benefits plans adequate. This is making voluntary benefits more important than ever in this age of the multigenerational workforce and a tight labor market. Read this blog post from for six voluntary benefits employees want.
In this age of the multigenerational workforce and a tight labor market, a one-size-fits-all group benefits model with medical, prescription, dental, vision and a retirement plan just doesn’t cut it. A workforce with Baby Boomers, Gen X’ers, Millennials and Generation Z means that employees are going to find the run-of-the-mill benefits plan inadequate. Ditto for job seekers.
What follows is that voluntary benefits are more important than ever. Offering a range of voluntary benefits can help meet the needs of employees at all life stages.
Voluntary benefits add value to benefit plans and are typically easy to administer. They’re low-to-no-cost because employees pay for them, and maintenance is often handled through a payroll deduction. Many voluntary benefits also offer guaranteed acceptance at a lower rate than medical benefits, so even if a small group within your company chooses a particular benefit, they’ll be covered.
This landscape is changing quickly. Here are six trending voluntary benefits your employees want.
Student loan debt repayment assistance
Debt among college graduates has grown to nearly $1.6 trillion. It’s preventing the largest employee segment at most companies from buying houses or cars, saving for retirement, having kids and getting married. To help employees repay their student loan debt, some employers are helping employees pay down student loan debt through a direct payroll deduction.
Others are offering a new, IRS-allowable retirement plan match swap where an employer can opt to increase its defined contribution match, enabling employees to reduce their retirement match and contribute funds to repaying student loans instead.
Interest in this benefit continues to grow. Employers looking to offer student loan debt repayment should be aware that not all platforms are created equal. Look out for high per-employee, per-month fees.
Individual long-term care
A growing number of people are beginning to understand the value of long-term care insurance because they have taken care of or currently care for a friend or relative who needs round-the-clock care. Long-term care insurance covers home or institutional care if a person is no longer able to perform at least two activities of daily living--eating, bathing, dressing, moving from a bed to a chair or using a toilet.
Employees are interested in buying long-term care insurance through their employer because they can offer better rates for simplified issue plans. If you plan to offer long-term care as an employer-sponsored benefit, I recommended rolling it out with a strategic project plan and a benefit counselor or a technology platform capable of providing decision-making tools for a smooth application process.
Executive reimbursement plans
Employee retention — especially executive retention — is on the minds of many employers in the midst of this thriving economy. Filling gaps in medical and prescription coverage is one way to provide executive teams with premium benefits they may be looking for.
Executive reimbursement plans provide reimbursement for out-of-pocket expenses, access to facilities and level of service not normally covered under most group health plans. Rather than simply increasing compensation to help cover out-of-pocket expenses, premiums for these plans are tax-deductible for the employer, and benefits are non-taxable for employees.
Executive individual disability insurance
Traditional employer-sponsored long-term disability (LTD) is likely not enough coverage for highly-compensated employees or some sales staff who depends heavily on commission and bonuses. Normally, LTD pays employees 50-70% of their salary up to a certain amount.
Employers can carve out additional coverage for employees based on their management level, performance or tenure. Individual disability insurance plans can protect employees until they turn 65; they can also protect job titles or levels until employees are well enough to return to work. Executive individual disability insurance, like executive reimbursement, can be offered as a form of compensation, or a form of financial asset protection for higher incomes.
Telemedicine
The rise of consumer-driven health plans has led to the need for telemedicine. Telemedicine provides a way for employees to see a physician or provider by video and get a diagnosis and/or prescription quickly. The success of telemedicine is leading some carriers to integrate it within their plan. However, standalones still exist and can provide employees with an easy way to get care faster and cheaper than before.
Pet Insurance
Pet parents spend nearly $70 billion on veterinarian costs for their pets, but just 10% of dogs and 5% of cats are covered by medical insurance. As pets begin to play a larger role in our lives, more employers are offering pet insurance to their employees to help defray the cost of unexpected medical expenses.
There are a number of plan options, and setting up a plan for employees’ pets is simple. However, it’s vital that employers do their research to ensure the veterinarian network includes the best vets.
As part of a voluntary benefit offering, be sure to develop a rollout strategy and communications plan so employees are thoroughly educated and you meet group minimums.
SOURCE: Park, N. (25 September 2019) "6 voluntary benefits your employees want" (Web Blog Post). Retrieved from https://www.benefitnews.com/list/6-voluntary-benefits-your-employees-want
8 renewal considerations for 2020
Are you prepared for open enrollment 2020? With renewal season quickly approaching, plan administrators have a lot of considerations to make regarding employee health plans. Read the following blog post from Employee Benefit News for eight things to consider this year.
The triumphant return of the Affordable Care Act premium tax (the health insurer provider fee).
This tax of about 4% is under Congressional moratorium for 2019 and returns for 2020. Thus, fully insured January 2020 medical, dental and vision renewals will be about 4% higher than they would have been otherwise. Of note, this tax does not apply to most self-funded contracts, including so-called level-funded arrangements. Thus, if your plans are presently fully insured, now may be a good time to re-evaluate the pricing of self-funded plans.
Ensure your renewal timeline includes all vendor decision deadlines.
As the benefits landscape continues to shift and more companies are carving out certain plan components, including the pharmacy benefit manager, you may be surprised with how early these vendors need decisions in order to accommodate benefit changes and plan amendments. Check your contracts and ask your consultant. Further, it seems that our HRIS and benefit administration platforms are ironically asking for earlier and earlier decisions, even with the technology seemingly improving.
Amending your health plan for the new HSA-eligible expenses.
In July of this year, the U.S. Treasury loosened the definition of preventive care expenses for individuals with certain conditions.
While these regulations took effect immediately, they won’t impact your health plan until your health plan documents are amended. Has your insurer or third-party administrator automatically already made this amendment? Or, will it occur automatically with your renewal? Or is it optional? If your answer begins with “I would assume…,” double-check.
Amending your health plan for the new prescription drug coupon regulations.
As we discussed in July of this year, these regulations go into effect when plans renew in 2020. In short, plans can only prevent coupons from discounting plan accumulators (e.g., deductible, out-of-pocket maximum) if there is a “medically advisable” generic equivalent.
If your plan is fully insured, what action is your insurer taking? Does it seem compliant? If your plan is self-funded, what are your options? If you can keep the accumulator program and make it compliant, is there enough projected program savings to justify keeping this program?
Is your group life plan in compliance with the Section 79 nondiscrimination rules?
A benefit myth that floats around from time to time is that the first $50,000 in group term life insurance benefits is always non-taxable. But, that’s only true if the plan passes the Section 79 nondiscrimination rules. Generally, as long as there isn’t discrimination in eligibility terms and the benefit is either a flat benefit or a salary multiple (e.g., $100,000 flat, 1 x salary to $250,000), the plan passes testing. Ask your attorney, accountant, and benefits consultant about this testing. If you have two or more classes for life insurance, the benefit is probably discriminatory. If you fail the testing, it’s not the end of the world. It just means that you’ll likely need to tax your Section 79-defined “key employees” on the entire benefit, not just the amount in excess of $50,000.
Is your group life maximum benefit higher than the guaranteed issue amount?
Surprisingly, I still routinely see plans where the employer-paid benefit maximum exceeds the guaranteed issue amount. Thus, certain highly compensated employees must undergo and pass medical underwriting in order to secure the full employer-paid benefit. What often happens is that, as benefit managers turnover, this nuance is lost and new hires are not told they need to go through underwriting in order to secure the promised benefit. Thus, for example, an employee may think he or she has $650,000 in benefit, while he or she only contractually has $450,000. What this means is the employer is unknowingly self-funding the delta — in this example, $200,000. See the problem?
Please pick up your group life insurance certificate and confirm that the entire employer-paid benefit is guaranteed issue. If it is not, negotiate, change carriers, or lower the benefit.
Double-check that you haven’t unintentionally disqualified participant health savings accounts (HSAs).
As we discussed last December, unintentional disqualification is not difficult.
First, ensure that the deductibles are equal to or greater than the 2020 IRS HSA statutory minimums and the out-of-pocket maximums are equal to or less than the 2020 IRS HSA statutory maximums. Remember that the IRS HSA maximum out-of-pocket limits are not the same as the Affordable Care Act (ACA) out-of-pocket maximum limits. (Note to Congress – can we please align these limits?)
Also, remember that in order for a family deductible to have a compliantly embedded single deductible, the embedded single deductible must be equal to or greater than the statutory minimum family deductible.
Complicating matters, also ensure that no individual in the family plan can be subject to an out-of-pocket maximum greater than the ACA statutory individual out-of-pocket maximum.
Finally, did you generously introduce any new standalone benefits for 2020, like a telemedicine program, that Treasury would consider “other health coverage”? If yes, there’s still time to reverse course before 2020. Talk with your tax advisor, attorney, and benefits consultant.
Once all decisions are made, spend some time with your existing Wrap Document and Wrap Summary Plan Description.
For employers using these documents, it’s easy to forget to make annual amendments. And, it’s easy to forget, depending on the preparer, how much detail is often in these documents. For example, if your vision vendor changes or even if your vision vendor’s address changes, an amendment is likely in order. Ask your attorney, benefits consultant, and third party administrators for help.
SOURCE: Pace, Z. (Accessed 9 September 2019) "8 renewal considerations for 2020" (Web Blog Post). Retrieved from https://www.benefitnews.com/list/healthcare-renewal-considerations-for-2020