Now that we have pushed through the busy season of renewals for clients who took advantage of ‘transitional relief’ under the Affordable Care Act (ACA), we are getting ready for another busy holiday season that kicks off with open enrollment for both the senior and individual markets in October and November, respectively, as well as 2016 tracking and reporting for Applicable Large Employers (ALE’s) and self-funded groups. We are also gearing up for 2017 by making more compliance resources and HR materials readily available to clients with the rollout of MyWave Connect.
We are continuously working to make sure we are bringing you the information and support you need to continue offering benefits in the increasingly complex world of healthcare. Although many of the challenges are the same, we recognize that each situation and every organization is a little bit different. Please be sure to let us know what we can do to help you and your organization succeed.
Open Enrollment – Individual Market / Senior Market
Believe it or not, November 1st marks the 4th open enrollment season for the Health Insurance Marketplace formed under the ACA. The public exchange has been getting a lot of publicity lately with high projected cost increases coupled with a multitude of carriers pulling out of the exchanges in many regions across the country. Apparently it is tough to be profitable when you are in the risk management business and you are not allowed to know anything about the risk.
In Ohio we are poised for major changes to the individual market. The leading writer of individual coverage in the state since the passage of the ACA, Medical Mutual of Ohio, filed their 2017 program to only be available in 32 of Ohio’s 88 counties. Within those 32 counties, the choice of providers is significantly smaller than the PPO networks of the past. Other carriers such as Aetna, Humana and UnitedHealthcare have virtually pulled out of the individual market in Ohio altogether. Anthem continues to offer individual coverage, but like Medical Mutual, with a more limited choice of providers than their typical Blue Cross / Blue Shield network. A few other carriers will also participate, most of which are Medicaid HMO’s that operate in distinct regions of the state. Needless to say, the public exchanges are going to have to change drastically if they are ever going to survive as a viable long-term option.
In the senior market, very little has changed in recent years, and 2017 appears to be no different. We continue to work with Medicare eligible individuals to obtain supplemental coverage, Advantage plans, and Part D prescription drug plans. Open enrollment for Part D runs from October 15th through December 7th, so if you or someone you know is evaluating options for Part D, the clock is ticking.
Affordability – HRA’s and Opt-Out Payments
Affordability under the ACA was intended to be straightforward: If an employee was required to pay more than a stated percentage of their individual income for single coverage under their employer’s health plan, then the employee may be entitled to a premium subsidy on the individual exchange, and the employer may be subject to a monetary penalty. Simple enough. But since that time, the question of how to account for the value of the funding of a health plan, or what should be constituted as income, has received a great deal of guidance and instruction from HHS, the DOL, the Treasury Department, and the IRS.
IRS Notice 2015-87 provided guidance on top of guidance that had previously been released in IRS Notice 2013-54. In short, both of these notices dealt with the value of Health Reimbursement Arrangements (HRAs) and opt-out payments that could be received or forfeited by an individual based on whether they did or did not participate in an employer’s health plan. For example, if an employee was eligible to receive money from an employer in lieu of signing up for the health plan, then that amount of money has to be considered part of the cost of the plan if the employee chooses to sign up for the plan and forfeits the ‘opt-out’ funds.
Because so much rides on the determination of affordability, both for employees and employers, the bottom line is that if an employer offers HRA’s or opt out payments to their associates, it is important to do a little research and make sure that your affordability calculations are being determined properly.
As with everything, there is more to do and less time to do it. Our clients are stretched thin, doing more with less, and there’s less time to digest all of the information that is available and determine what is relevant. At least with respect to healthcare and HR, we are trying to do our part to simplify that task.
MyWave Connect (MWC) is a complimentary online HR portal we are providing to TAH Benefits clients that can deliver time-saving benefits and HR resources whenever you need them. When initially getting setup with MWC, you are able to tailor the portal content to address those topics that are most important to you. Literally thousands of documents and articles centered on employee wellness, education, HR forms and other employee communication pieces are at your fingertips.
Please be on the lookout for an activation email with instructions on how to log on and setup MyWave Connect. Once you have everything setup, we hope you will find the content valuable and beneficial.