Although we’re already 6 weeks into 2016, it feels as though we are just now able to put 2015 in the rearview mirror. January renewals are now up and running; ‘Grandmothered’ groups are 2 months into their new plan year; Medicare Part D enrollment came and went; individual open enrollment is now completed. As we look back, both 2014 and 2015 have been extremely busy but successful years for us, and we have you, our clients, to thank for that. Looking ahead to the remainder of 2016, we expect to continue to grow and evolve as the needs of clients do likewise.
I expect compliance to continue to occupy much of our conversations with you. The addition of Caroline Sanker in mid-2015 as our Compliance Advisor is one illustration of our increased capabilities as well as our commitment to providing the resources our clients need in order to navigate the new, ever-changing world of health insurance. Continuing to work with our ALE clients to ensure their accurate 1094 and 1095 reporting, and preparing all clients for potential DOL audits, will be our principal compliance objectives for the remainder of 2016.
2016 will also usher many new group products into the market, specifically in the small group segment in response to modified community rating. Level-premium self-funded products are still evolving and gaining traction, and MEWA’s (Multiple Employer Welfare Arrangements) are re-emerging from their storied history as a method of bundling groups together for the purchase of group insurance. Many of these products will use limited distribution channels, available only to select agents within a given market. We are pleased to be included on all of those select lists, which allows us to offer all of the product options and arrangements available to date. As those options continue to be developed, we will continue to evaluate them as possibilities, sharing the pros and cons of each with you, to determine the best approach to managing your plan.
We appreciate the working relationship we have with you and the trust you have placed in us. Please continue to let us know how we can assist you and help simplify your world in the coming year.
Anthem 2-50 Clients Small Group Verification
As part of the Affordable Care Act and the passage of the PACE Act in late 2015, the definition of what constitutes a small group versus a large group was finalized. Instead of increasing the number of full-time employees up to 100 as was originally called for in the ACA, states are allowed to continue using 50 employees as the cutoff between small group and large group. Ohio is one of the many states that has chosen to continue using 50 and below to define small groups, thereby leaving groups with over 50 employees to be experience rated and groups with 50 or fewer employees subject to modified community rating.
With these final regulations, the insurance carriers have each come out and defined what they will use to calculate ‘employees’. In the past most carriers used ‘full-time eligible’ for their counts, however since the passage of PACE, many companies are now using ‘total employees’ to determine a group’s small / large group status. In order to accurately make this determination, Anthem is requesting that all of their current small group clients provide the attached Attestation Statement to disclose whether or not the group had 50 or fewer total employees during the preceding calendar year. In order to make sure these are submitted prior to processing for the 2016 renewals, we are asking that all Anthem groups return these forms to us as soon as possible, but no later than May 1st. Please either email to Jill Davis at email@example.com, or via our toll-free fax at 888-284-1529.
UnitedHealthcare Early Renewal Verification Request
Barring further changes or delays, small groups who have taken advantage of ‘grandmothering’ – keeping what they had for another 2 years – are scheduled to move to adjusted community rating, beginning with renewals occurring after October 1, 2016. Many carriers have already moved most of their ‘grandmothered’ groups to an October 1, 2016 renewal date and now the same is being offered to UnitedHealthcare clients. Completing the attached Verification Form will allow small groups who are scheduled to renew after October 1, 2016 the opportunity to move their renewal date to October 1, 2016, thereby giving them the chance to ‘keep what they have’ for at least one more year before being forced into adjusted community rating under the ACA.
We are recommending that all small groups who are currently ‘grandmothered’ take advantage of this opportunity. To do so, please return the attached Verification Form to us prior to March 15th, either by email to Jill Davis at firstname.lastname@example.org, or via our toll-free fax at 888-284-1529.
Part D Disclosure to CMS
One of the commonly overlooked tasks that a group offering an employer-sponsored health plan fails to perform is the annual disclosure to CMS of the status of the group’s prescription coverage relative to Medicare Part D. While we provide the individual notices an employer can use to notify Medicare-eligible individuals of the group’s plan status relative to Medicare Part D, we are not able to register on-line with CMS to make the necessary reporting on behalf of the employer. The attached Legislative Brief explains the requirement in more detail and contains the link that is necessary in making the disclosure.
If there are further questions about this requirement or if you need additional assistance, please give us a call.
Jay Hazelbaker, President