Private Exchanges May Offer Shelter from Cadillac Tax

Originally posted April 03, 2014 by Allen Greenberg on http://www.benefitspro.com

COLORADO SPRINGS, Colo. – Avoiding, or at least putting off, the so-called Cadillac tax in the Patient Protection and Affordable Care Act is on a lot of employers’ minds.

Speaking Wednesday at the 2014 Benefits Selling Expo, William Stuart, a lead consultant at Wellesley, Mass.-based Harvard Pilgrim Health Care, suggested that one of the best ways to do so is by moving employees to one of the burgeoning number of private insurance exchanges.

That alone won’t do the trick, he said, but shifting to an exchange can help “reset the premium base” and “bend the cost curve” – the two things necessary if employers hope to postpone the pain of the excise tax.

The tax – meant to raise money to offset the government’s subsidies to lower-income individuals and families buying insurance under the PPACA – goes into effect in 2018. It is a 40-percent penalty on premium dollars above $10,200 for individuals and $27,500 for families.

This tax is probably not going to go away,” Stuart said. “It might. But we can’t base our strategy on what may or may not happen.”

The premium levels at which the tax is calculated, he said, will include medical premiums, health flexible spending arrangement elections, health reimbursement arrangements and employer contribution to HSAs. “In other words,” he said, “the law has taken some tools (for reducing or putting off the tax) off the table.”

But options do exist, he said, and the sooner employers act, the better, meaning the later the tax will impact them.

Stuart said brokers should consider encouraging their clients to establish wellness programs. The return on investment is often difficult to gauge on wellness, he noted, but a healthier workforce tends to mean fewer health problems, which helps bend the cost curve.

A narrower provider network can also help, he said, especially one that might exclude teaching hospitals where costs tend to be higher.

Stuart acknowledged people prefer all kinds of choices in which doctors they see or which hospital they might use. But that fades once they realize they can save up to 25 percent of their costs.

Health savings accounts, meanwhile, are another option for employers looking to reduce costs, because they encourage employees to be more careful with their health care dollars.

In the end, however, private exchanges may yield the most dramatic results, Stuart said.

Among their advantages: an array of health plans offering in some cases as much as a 40-percent spread in premium costs.

Once in an exchange, the employee mindset shifts to saving money, rather than simply buying without shopping. People, Stuart said, tend to buy down in an exchange once they realize they might have been over-insured. This, too, helps reset the base.

Aon Hewitt, the large employee benefits consultancy, which last year launched its Aon Hewitt Corporate Health Exchange, recently said the average cost increase for three fully insured large companies in its exchange was 5.1 percent.

By comparison, average cost increases for large U.S. employers are projected to be between 6 and 7 percent in 2014, according to Aon Hewitt’s annual cost trend data report.


Americans will have an extra six weeks to buy health coverage before facing penalty

Originally posted by Sandhya Somashekhar, Amy Goldstein and Juliet Eilperin on http://www.washingtonpost.com

The Obama administration said last Wednesday night that it will give Americans who buy health insurance through the new online marketplaces an extra six weeks to obtain coverage before they incur a penalty.

The announcement means that those who buy coverage through the exchange will have until March 31 to sign up for a plan, according to an official with the Department of Health and Human Services.

Administration officials said that the rejiggered deadline is unrelated to the many technical problems that have emerged with the Web site, HealthCare.gov, in its first three weeks. Instead, they said, it is designed to clear up a timing confusion about the 2010 law, which for the first time requires most Americans to buy health coverage or face a penalty.

Under the law, health plans available through the new federal or state marketplaces will start Jan. 1, but the open enrollment period runs through the end of March. The law also says that people will be fined only if they do not have coverage for three months in a row. The question has been this: Do people need to be covered by March 31, or merely to have signed up by then, given that insurance policies have a brief lag before they take effect?

The administration made clear Wednesday night that people who buy coverage at any point during the open enrollment period will not pay a penalty.

It is the latest sign that the health-care law remains a moving target, even after the launch of the federal insurance marketplace, which has faced myriad problems that have frustrated many people trying to sign up for coverage.

Contractors and others have begun assigning blame for the Web site troubles, and the fault-finding will get its first extensive public airing Thursday, when four of the contractors involved in the project will testify before the House Energy and Commerce Committee.

In the written testimony submitted to the panel in advance, CGI Federal, the main contractor on the project, takes partial blame for the site’s shortcomings. But it also notes that the Centers for Medicare and Medicaid Services (CMS), an agency within HHS, was the “ultimate responsible party for the end-to-end performance” of the site. And it blames a piece created by another contractor, Quality Software Services (QSSI), for creating the initial bottleneck.

QSSI built part of the online registration system that crashed shortly after the Oct. 1 launch and locked out many people for days. In a statement, the company counters that it was not the only one responsible for the registration system, which is now working.

“There are a number of other components to the registration system, all of which must work together seamlessly to ensure registration,” said Matt Stearns, a spokesman for UnitedHealth Group, the parent company for QSSI. “The [QSSI-built] tool has been working well for weeks.”

But both contractors are likely to be taken to task by Republican and Democratic committee members. They were among the vendors who testified at a Sept. 10 Energy and Commerce Committee hearing that their parts of the project were moving along well, and that the Web site would be ready Oct. 1. Those assurances are likely to be questioned Thursday.

The hearing is the first of many planned by Republicans, who are expected not only to question the contractors but also to examine the administration’s management of the project. Some Republicans have called for the ouster of HHS Secretary Kathleen Sebelius, who is scheduled to appear before the panel next Wednesday.

President Obama and his deputies have given no indication that they are considering replacing Sebelius. White House press secretary Jay Carney has consistently defended her, and officials have been focusing on fixing the site rather than assessing blame for its defects.

The administration, however, has sought to assure jittery business leaders and insurers that can fix the enrollment system. On Tuesday, Vice President Biden told business supporters in a conference call that the nation’s best technology minds were working on the site and urged them to “stick with us.” And on Wednesday, top Obama advisers met with insurance executives to discuss system repairs.

CMS had enormous responsibility, and was charged with ensuring that there would be a mechanism for millions of Americans to easily sign up for coverage in time for some of the law’s main benefits to begin Jan. 1. Officials have said ease of signing up is critical to the administration meeting its goal of getting 7 million uninsured people — many of them young and healthy — to sign up.

But the agency assumed an outsize role in the management of the project, coordinating the activities of 55 contractors rather than hiring a separate firm to serve as a systems integrator. That is likely to be a key issue during Thursday’s hearing.

People familiar with the project have said the time frame was too tight for adequate testing, which one source said would have highlighted the problems.

There also have been inconsistencies about how and when the decision was made to scrap a key feature of the Web site, with QSSI telling congressional investigators that it did not know about the major change until the site’s launch. But in the written testimony the company plans to deliver Thursday, it says it found out shortly before the rollout date.

Republicans have been eager to learn more about how and when the decision was made to end that feature. The feature would have allowed people to browse plans and rates before signing up for an account. Technology experts have said the last-minute decision to stop it put too much pressure on a different tool that was set up to handle a small number of simultaneous users, crashing the site.

People familiar with the project give conflicting accounts of the reason for the move. The decision was made at a two-day meeting in late September to which CMS invited all its major contractors. According to one person familiar with the project, CGI gave a presentation that convinced CMS officials that the shopping feature was not ready.

Another person close to the project had a slightly different account, saying that CGI believed that the feature was, in fact, ready.

Republican lawmakers have alleged that the administration made the change to hide the cost of insurance plans from consumers.

“Evidence is mounting that political considerations motivated the decision,” said a letter sent to two administration officials Tuesday from members of the House Oversight and Government Reform Committee, including Chairman Darrell Issa (R-Calif.).

Lena H. Sun, Ed O’Keefe and Tom Hamburger contributed to this report.


Health Q&A: ‘Obamacare’ Exchanges Start as Questions Abound

Originally posted September 30, 2013 by Alex Nussbaum on http://eba.benefitnews.com

Obamacare’s insurance exchanges debut tomorrow and so far the run-up has looked a lot like a political campaign, with dueling TV ads, door-knocking volunteers and a focus on swing-state targets.

Just don’t expect the usual ending to an election: a clear winner at the end of the day.

While the exchanges are expected to open on time, that milestone is unlikely to settle the 3 1/2-year grudge match over the Affordable Care Act. A long enrollment season, complicated by a threatened U.S. government shutdown and a growing list of technical glitches, means it may be as late as April before it’s known how many uninsured Americans sign up under the law.

While the shutdown won’t stop the roll-out, which is largely funded through mandatory appropriations that can’t be curtailed by congressional inaction, it’s an open question whether it will lessen public enthusiasm to enroll. In the meantime, technical glitches are beginning to surface.

People in Oregon, for example, won’t be able to enroll in a plan for the first few weeks unless they go through a broker or designated nonprofit groups, and the exchange in the nation’s capital won’t include premium prices until mid-November.

The Obama administration says other glitches are inevitable as the system starts up. The question is how serious and how long it takes the exchange to fix any issues. An extended crash or a problem calculating subsidies could be an embarrassment for the White House -- and sour consumers just as the administration tries to convince them to enroll.

‘In Between’

“Is it going to be a train wreck, a complete failure? The answer is no,” said Dan Schuyler, a director at Leavitt Partners, a Salt Lake City-based health care consultant. “Is it going to be completely seamless and instantaneous? No. It is going to be somewhere in between.”

The exchanges are at the heart of the law’s efforts to cover more of the 48 million uninsured Americans. About 7 million people will use the system to buy subsidized insurance by the end of the first open enrollment period on March 31, according to congressional projections.

Republicans will spotlight any problem as proof the law is a disaster. Democrats say they’ll overcome technical glitches and the law will sell itself as the uninsured gain benefits. Polls show most Americans side with the skeptics.

“The lights will go on Oct. 1, but they may flicker,” said Jocelyn Guyer, a director at the Washington-based consultant Manatt Health Solutions. “I worry the most about people making premature judgments on the first couple of weeks.”

The Breakdown

Here’s a primer on what to look for, based on interviews with consultants, insurers, analysts and state and federal officials:

Q: Who runs the exchanges?

A: Fourteen states have their own on-line exchanges, with the rest run in whole or part by the U.S. government.

Q: Who will use them?

A: The exchanges are open to people who buy coverage on their own and employees of businesses with 50 or fewer workers, as well as those currently shut out of insurance because of cost or a medical condition.

Subsidies are available, on a sliding scale, to those making as much as four times the poverty level, which is $11,500 for a single person and $24,000 for a family of four. Those making less than 138% of poverty will be eligible for Medicaid if they live in one of the 26 states set to expand the program.

Sign-Up Numbers

Q: How many people will sign up early on?

A: Call it lowering expectations or a realistic assessment: either way, supporters say they don’t expect a flood of enrollees this week.

Insurance buyers have to pay their first month’s premium within 30 days of choosing a plan and the policies don’t take effect until Jan. 1. As a result, the Obama administration says most people will wait until late November or December. Another surge may come in March as the end of the enrollment period nears.

Q: What happens if the federal government shuts down?

A: The exchanges will march on. That’s because the 2010 law relies primarily on mandatory spending, which congressional inaction can’t stop. It’s the budget category used for benefits such as Medicare, the U.S. health plan for the elderly and disabled, and Social Security.

The U.S. Health and Human Services Department said in a Sept. 27 memo it “would continue large portions of ACA activities, including coordination between Medicaid and the marketplace” in the event of a temporary shutdown.

Core Unaffected

“Many of the core parts of the health-care law are funded through mandatory appropriations and wouldn’t be affected,” Gary Cohen, the director of the Center for Consumer Information and Insurance Oversight at HHS, told reporters on Sept. 24.

Q: Okay, so most of the exchanges will be up and running on time. How do you access them?

A: If all goes as planned, those not covered through work will be able to go on line or dial a call-in center, learn if they’re eligible for tax credits and choose from a menu of private plans. The exchanges can be found atwww.healthcare.gov.

Q: Who won’t use them?

A: Most of us. People who have insurance through their jobs, about 55% of Americans, aren’t directly affected by the law and are automatically in compliance with its mandate that everyone be insured. So are older Americans covered through Medicare.

Individual Mandate

Q: Do I have to buy insurance?

A: Yes, or pay a fine. The law requires that most Americans be insured starting Jan. 1. That can be through work, a government program like Medicare or Medicaid, or by buying on the exchanges. Those who opt out face a penalty starting next year at $95 or 1% of household income, whichever is higher. By 2016, it rises to $695 per individual or 2.5% of household income, whichever is greater.

Q: Is the technology for the exchanges in place?

A: Building the exchanges has been a massive technical lift, requiring computer systems with real-time links to dozens of state and U.S. agencies and private carriers. The administration says the system is ready to go, albeit with delays and reduced capabilities in places like Oregon and Washington.

Company Mandate

Q: Has anything else been delayed?

A: The law requires that large companies offer benefits to anyone working more than 30 hours a week. In July, that rule was postponed until 2015 to ease the burden of compliance.

Last week, officials said a Spanish-language version of the federal website won’t be ready until mid-October and an exchange for small business workers won’t take enrollments until November. Nevada and California also won’t transmit names of new customers to insurers for about a month, Schuyler said.

Q: Will the coverage be affordable?

A: It depends on who you are and where you live. Six in 10 uninsured people will find insurance for less than $100 a month because of subsidies and expansions to Medicaid, the administration said last week. Those who make too much for assistance may be in for sticker shock: the same report said even bare-bones coverage, known as a bronze plan, will average almost $3,000 a year for individuals.

For families, the cost of mid-level coverage, a silver plan, ranges from $559 a month to $1,216 a month in 36 states where the federal government controls the exchanges. Tax credits will reduce the cost for many: a family earning $50,000 a year may find the price of a bronze plan cut to zero in some states.

Young and Healthy

Q: How will insurers cover the costs for all those added sick people?

A: By signing up the young and healthy. The administration said it needs about 40% of new enrollees to be in this group to help balance costs from older, sicker customers and keep premiums stable.

Q: Do Americans understand what they’re getting into?

A: No. The polls indicate consistent confusion. Three in five say the law will raise medical costs, and more say they’ll be worse off under it than better, according to a Bloomberg National Poll conducted Sept. 20-23. Half also said Republicans should back off on demands to defund the law, a schizophrenic view that’s persisted for months.

Q: So does anybody like this law?

A: Yes. Sixty-one percent of Hispanics and 91% of blacks, according to a September poll by the Pew Research Center and USA Today. That could make the sales pitch easier because those two groups comprise the bulk of the uninsured in the U.S. – 47% of the total, according to an analysis by the Kaiser Family Foundation. The law also is designed to benefit people with pre-existing medical conditions: insurers will no longer be able to deny them coverage.

Big States

Q: What’s happening in the big states?

A: Supporters have focused on states such as TexasFloridaOhio and New Jersey, where many uninsured live and Republican governors refuse to help in enrollment. California, which has the most uninsured, is spending $100 million to promote its exchange while New York plans to spend $27 million to train community groups and brokers to assist consumers.

Q: How much help do consumers get?

A: The administration is spending $67 million to train health workers, hospitals and other groups, called navigators, to help people enroll. Grants didn’t arrive until August, though, and many began a two-week training course this month. If they’re not up to the task, enrollment may suffer.

“You’re going to have tens of thousands if not hundreds of thousands of individuals who have never been exposed to health insurance before -- don’t know what a premium is, what a deductible is,” said Schuyler, the Leavitt Partners consultant.

Changes Needed

Q: Do Democrats think the law needs to change?

A: Some have called for changes: Families of workers whose company plan doesn’t include dependents can’t get subsidies. A tax credit for small businesses has been criticized as ineffective. And there are bipartisan bills in Congress to change a provision that may encourage businesses to cut workers’ hours to avoid insuring them. A quick fix seems unlikely: Republicans say they won’t tinker with a law they consider fundamentally flawed.

Q: What’s happening with Medicaid?

A: While the government health program for low-income Americans is expanding under the law, about half the states have opted out. The Obama administration last week agreed to let Arkansas use the money to help poor citizens buy private insurance on its exchange. The deal could entice other states where Republicans have opposed the expansion.

Expense Rising

Q: Is Obamacare making health-care more expensive?

A: Time will tell.

Medical costs have moderated in the U.S. the past three years, offering some relief to the public and private sectors alike. Prices for medical care rose 1% in July compared with a year earlier, the lowest growth rate since the 1960s, according to U.S. Commerce Department data.

There’s a debate among economists about how much credit to give the health law compared with a weak economy and employer moves to curtail benefits. Obamacare supporters say at least some of the slowdown is thanks to regulations and pilot programs in the act aimed at reducing waste in the medical system.

 


HHS releases federal exchange rates

Originally posted by Allison Bell on September 25, 2013 on http://www.benefitspro.com

With the public exchanges under the Patient Protection and Affordable Care Act preparing to open their phone lines and their Web enrollment sites Tuesday, the Obama administration is getting closer to revealing what federal exchange plans might actually cost.

A health policy office at the U.S. Department of Health and Human Services on Wednesday released a report showing what the average starting price for individual bronze, silver, gold and catastrophic exchange coverage will be for a 27-year-old in each state in which HHS will be running a "federally facilitated exchange."

The report also shows what the starting price for each level of individual coverage will be in the biggest city in each FFE state; what a 27-year-old individual coverage buyer with an annual income of $25,000 and access to exchange tax credits would pay for the lowest-cost coverage out of pocket; and what a family of four with an annual income of $50,000 would payout-of-pocket if it did or did not have access to the tax credits.

In Texas, for example, the average cost of the cheapest bronze coverage available to a 27-year-old would be $139 per month. The average cost of the cheapest gold coverage available would be $225 per month.

In Houston, the state's largest city, bronze coverage for the 27-year-old would start at $138 per month.

A look at medically underwritten 2013 rates available from eHealthInsurance.com for a 27-year-old who lives in Houston suggests that typical carriers there would now charge that consumer about $100 to $300 for coverage per month, with a majority charging $100 to $200 per month.

The family of four might have to pay $727 per month for silver coverage if it had no tax credits. Tax credits could cut the monthly cost of the coverage to $282.

Vermont posted preliminary exchange rates in April, and State Refor(u)m has posted a map showing that 27 states and the District of Columbia had at least posted preliminary rates for their state-based or federally facilitated exchanges as of Monday.

HHS — the parent of the Centers for Medicare & Medicaid Services, the agency running the exchanges — has repeatedly postponed the release date for FFE rate information without explaining why.

Some states have used state public records laws to justify releasing FFE exchange plan information on their own.

Other states, including Texas, have treated the FFE plan rates as confidential information.

HHS officials said the cost of the "second lowest cost silver plan" in the District of Columbia and 47 states is 16 percent lower than what HHS had expected, based on Congressional Budget Office projections.

HHS Secretary Kathleen Sebelius said in a statement that high prices have shut many consumers out of the health insurance market in the past.

"We excited to see that rates in the marketplace are even lower than originally projected," Sebelius said.


DOL Says No Fine for Failing to Provide Exchange Notices in 2013

Originally posted by Stephen Miller on September 13, 2013 on http://www.shrm.org

U.S. employers were again surprised by another unexpected suspension of a provision of the Patient Protection and Affordable Care Act (PPACA or ACA) when, on Sept. 11, 2013, the Department of Labor (DOL) announced there will be no penalty imposed on employers that fail to distribute to workers a notice about available coverage under state- and federal-government-run health insurance exchanges (collectively referred to by the government as the "health insurance marketplace"), scheduled to launch in October 2013.

Fair Labor Standards Act (FLSA) Section 18B, added to the labor statute by the PPACA, requires employers that are subject to the FLSA to provide all their employees by Oct. 1 of each year (the traditional start of the annual open enrollment season for employee health plans), and all new employees at the time of hiring, a written notice informing them of the following:

  • The existence of the government-run health care exchanges/the marketplace, including a description of the services provided and the manner in which employees may contact an exchange to request assistance.
  • If the employer plan’s share of the total allowed costs of benefits provided under the plan is less than 60 percent of such costs, workers may be eligible for a premium tax credit under Section 36B of the Internal Revenue Code if they purchase a qualified health plan through an exchange.
  • Employees who purchase a qualified health plan through an exchange may lose their employer’s contribution to any health benefits plan the organization offers. All or a portion of this contribution may be excluded from income for federal income tax purposes.

According to the PPACA and subsequent guidance, the notice must be provided to each employee, regardless of plan-enrollment status or part-time or full-time status. Employers are not required to provide a separate notice to dependents or retirees, but an employer's obligation to provide notice may extend to its independent contractors and leased workers, depending on the nature of their relationship with the employer as determined under the FLSA's "economic reality" test.

The PPACA has a $100-a-day penalty for noncompliance with its provisions (unless otherwise specified in the statute), and it had generally been assumed this penalty would apply to employers that fail to distribute the exchange notice, possibly with additional penalties for failure to comply with a provision of the FLSA. However, the penalty provision had not been made explicit in any previous guidance, nor had the regulators described how the penalty would be implemented and enforced.

Then, on Sept. 11, 2013, the DOL posted on its website a new FAQ on Notice of Coverage Optionswhich states:

Q: Can an employer be fined for failing to provide employees with notice about the Affordable Care Act’s new Health Insurance Marketplace?

A: No. If your company is covered by the Fair Labor Standards Act, it should provide a written notice to its employees about the Health Insurance Marketplace by Oct. 1, 2013, but there is no fine or penalty under the law for failing to provide the notice.

DOL Encourages Compliance

Keith R. McMurdy, a partner at law firm Fox Rothschild LLP, commented in a posting on his firm’s Employee Benefits Legal Blog that Section 18B of the FLSA clearly states that any employer subject to the FLSA “shall provide” written notice to current and future employees and that the DOL’s Technical Release No. 2013-02, issued in May 2013, states that Section 18B of the FLSA generally provides that an applicable employer “must provide” each employee with a notice. McMurdy wrote:

My experience with the federal laws and the enforcement of said laws by federal agencies is that when things say “shall” and “must,” there are penalties when you don’t do them. So when the DOL now takes the position that it is not a “shall” or “must” scenario, but rather only a “should” and “even if you don’t we won’t punish you” proposition, I get suspicious. But I also think this confirms what I have said since the beginning about PPACA compliance for employers. It is all about your risk tolerance.” …

So, if you don’t want to send the Oct. 1, 2013 Notice, apparently the DOL “FAQ” says you have no penalties and thus no risk. Me? My risk tolerance is a little lower than that and my experience with regulatory agencies is such that I don’t trust informal “FAQs” posted on the web as much as I trust the clear language of the statutes and prior technical releases. Words like “shall” and “must” usually mean that if I don’t do it I get burned. So I am still recommending that employers comply with the notice requirement. Why? I can almost guarantee that if you send the notice, you won’t face a penalty for not sending it. But if you don’t send one, well, I still say all bets are off.

Christine P. Roberts, a benefits attorney at law firm Mullen & Henzell LLP,commented on her “E is for ERISA” blog, “This information, at this late date, is more confusing than it is helpful to employers who have already invested significant resources in preparing to deliver the Notice of Exchange.” She added this cautionary note:

“Particularly for employers with pre-existing group health plans, the Notice of Exchange potentially could be viewed by the DOL as within the scope of the employer’s required disclosures to participants and thus within the scope of an ERISA audit, or separate penalties could be imposed through amendment to the FLSA or the ACA.”

Model Notices

The DOL’s Sept. 11 FAQ reiterated that the department has two model notices to help employers comply with the Oct. 1 exchange/marketplace notice deadline (which they are strongly encouraged to meet):

Employers may use one of these models, as applicable, or a modified version. The model notices are also available in Spanish and MS Word format at www.dol.gov/ebsa/healthreform.


Be Prepared For Fall Open Enrollment Changes

Originally posted September 3, 2013 by Amy Gallagher on http://www.golocalworcester.com

The healthcare reform law requires employers to notify employees of available health exchange options by October 1. That means employees will face new health plan choices - and decisions - during open enrollment this year.

Education is Key

With new options comes the need for more education. And that doesn't just mean the health exchange option notice employers are required to provide, which is likely to confuse employees.

Since employees will get to choose between employer-sponsored plans or those offered by the exchanges for the first time, employers should make an extra effort with their communication plans for this fall's open enrollment. And employees should step up their participation in the process as well.

Employee questions...and answers

Employers should provide informative, detailed materials that will enable employees to evaluate their choices and make the best decisions. When reviewing open enrollment resources, employees should follow these five steps:

1. Review the benefits and costs of the employer-sponsored plan. Understand what the employee’s share of the cost is in dollars - an amount that's deducted pre-tax from your paycheck at whatever tax bracket you fall in. For example, an employee who pays $250 monthly of a $500 total monthly individual plan cost will have a deduction (assuming a 30% tax bracket) around $175 monthly.

2. Compare the employee costs above to an individual plan offered through a state-run exchange.Employees who are Rhode Island residents may visit www.HealthSourceRI.com and those who reside in Massachusetts can go to www.mahealthconnector.com for details. Keep in mind that employees who purchase an individual plan through the exchange must pay the full cost of the plan unless you qualify for tax credits to offset, or eliminate, the cost.

3. Determine tax credit by using an online tool and estimating family income for 2014 (before taxes), telling the age of the oldest adult in the family, and entering the total number of adults and children in the household. Generally, employees may be able to get a subsidy if they are single and make up to $45,960, or are a family of four and earn up to $94,200. The exact amount of the subsidy is determed by size of family and level of income, so the less someone makes, the more they will receive.

4. Employees who receive the subsidy should subtract the earned tax credits from the total cost of the exchange plan to determine their total premium cost. Then compare this amount to what you would pay for an employer-sponsored plan.

5. Last, all employees must understand that, starting January 1, 2014, they are mandated to be insured.Whether through an employer or exchange plan, it’s up to you to get coverage, or pay penalties at tax time.


Should exchanges be part of your company's plan?

Originally posted August 06, 2013 by Justyn Harkin on http://ebn.benefitnews.com

Although considering the new health care exchanges may have seemed radical a few weeks ago, now that everybody gets to drop ten and punton the employer mandate penalty in 2014, the idea may not be so strange.

Sure, migrating employees to the exchanges isn’t right for every organization. If the move would upset your workforce, then keeping your current group plan is probably best. But if employees would view exchange offerings as equal or better than what they current have, then there could be plenty of upsides.

If you think the exchanges would be better than what you have now for both your company and your employees, or even if you just want to get a leg up on communications (and believe me, that’s never a bad idea), then you and your employees have three options — public exchanges, private exchanges (fully insured), private exchanges (self-insured).

Which one might be best for your organization? Let's see.

Public exchanges

One of the most attractive ideas about moving to a public exchange has to be handing over the considerable financial and administrative burdens for running your company’s health benefits.

For some organizations, the move might be cheaper than what they are doing now. Even when you factor in the likely, eventual activation of the $2,000-per-employee fine for not providing insurance, you could still be paying less than what you would if you were covering premiums.

Of course, sending employees to public exchanges isn’t necessarily a slam-dunk move. Your workforce could straight-up riot if you tell them you’re cutting health benefits, and even if you raise salaries (oh, hello there, higher payroll taxes) to help them cover the costs of buying their own insurance, your recruiting efforts could take a hit if your competitors keep their health benefits.

Private exchanges with fully insured plans

Perhaps the biggest advantage of using a private exchange is the ability to shift some of the rising costs of health care to employees and give them the ability to control their spending.

In a private exchange, employees get an allowance from their employer that can be used to buy insurance. The idea is that giving employees control of the purchasing decision takes some of the heat off of your company. After all, if the cost of health care rises, that’s not your fault?

So what’s the downside to this type of exchange? Well, in the worse-case scenario it’s a less healthy, less productive workforce. Because employees will be making purchasing decisions, they may choose lower premiums over better coverage, and that can contribute to poorer health and higher rates of absenteeism.

Private exchanges with self-insured plans

The last of your exchange options are private exchanges with self-insured plans. Compared with the types of plans offered on public exchanges and private exchanges with fully insured plans, the plans available on private exchanges with self-insured plans can seem very attractive employees — generally lower premiums, more generous plan features, and more in-network doctors — but they will be more expensive.

The self-insured private exchange option might be slightly more expensive than what you could do with a fully insured private exchange, that’s true, but the available plans would be more oriented toward long-term health.

Still, using self-insured plans means you’ll have to assume all the risk and pay for all your employees’ claims. Also your employees will become customers of the private exchange insurance companies, and that means you won’t have the same influence (over the companies or choices) that you would otherwise have.

How will you spend the bonus year?

Assistant Secretary for Tax Policy Mark J. Mazur’s July 3 announcement might have seemed like the best health care reform–related thing to happen to employers all year.

If you take the “transition year” at face value, meaning the mandatory employer and insurer reporting requirements are being postponed, then you have the perfect chance to carefully consider your company’s next moves.

Maybe you’ll decide to take the plunge. Perhaps you’ll rule out the exchanges altogether. You might even decide to let other companies test the waters first so you can be prepared later on.

No matter what path you chose, though, the most important thing is taking the time to make the best decision for your company and your employees. And then communicate that decision in a clear and engaging way. Good luck!


Compliance Alert – Exchange Notice

Two versions of a model exchange notice have been issued by the Department Of Labor which also include basic directions on the requirements of distributing this notice. The first notice pertains to employers who provide coverage, whereas the other notice is for employers who do not offer coverage. The deadline for administering these notices is October 1st, 2013.

Basic employer information is required for both notices. This information will provide data necessary for the employee if they decide to receive exchange coverage. However, the notice does not need to include state-specific information pertaining to the exchange. For your convenience, the links below offer instructions and information on the model notices; and we will keep you updated with more information next week or as this is updated.

Model Exchange Notice for Employers who provide coverage

Model Exchange Notice for Employers who do Not provide coverage