Two Minute Drill

IRS Announces HSA/HDHP Limits for 2018

 

 

Perhaps this is early but you can file it.

IRS Announces HSA-HDHP Limits for 2018

 

 

Who knows where the federal healthcare regulations are going, but if the Republicans (and the President) pass anything it will likely affect the group market by:

  • Removing the cost share regulations
  • Reduce the reporting requirements
  • Allow carriers to create more types of plans

We will report on those types of things when/if the Senate releases their proposed version of a new healthcare bill .

Medicare Eligible Employees/Dependents…. Don’t Assume You Can Waive Part B

Medicare can be tricky when it is coordinating with Group Health Coverage.

This is especially true when Medicare enrollees WAIVE Part B coverage, thinking that they don’t need it because they have Group Health Coverage.

Our message to those people is BE CAREFUL. You must be certain that if you waive Part B coverage that you are not opening yourself up to claims exposure.

Never assume that a Group Health Plan will step in and cover claims.

Since CMS clearly states that the INDIVIDUAL is responsible to know (not the employer nor the insurance company) the Medicare coordination with other coverage, it is critical to be careful and do the research.

Here are some examples where things get tricky:

  • When an employer has fewer than 20 employees, Medicare is primary. With some insurance companies they do not even pay claims if Medicare does not approve. If one does not enroll in Part B, that means NOTHING is approved by Medicare. Translation: Costs that would have gone to Part B are not approved by Medicare and not approved by the insurance company. This is a big problem.
  • When an employer has fewer than 100 employees, Medicare that is DUE TO DISABILITY is primary. The same rules apply.
  • When someone is on COBRA and Medicare, Medicare is primary no matter how many employees the employer has. If the member on COBRA waives Part B, they face potential liability. People could easily assume that the rules would be the same as when they were active on the plan (vs COBRA), but that would be a mistake.

While we at BBG will help our clients get the right answer and try to fix things if someone has assumed the wrong thing, we urge everyone who is Medicare eligible to engage to find the right answers. We are not responsible for errors in Medicare enrollment, but we can be a resource for assistance.

No one should assume that waiving Medicare Part B coverage will be just fine. Getting the right answers and keeping the documentation is critical if you waive Part B.

Medicare 101

Now That ACA Remains in Place Maybe We Should Keep An Eye On This Recent HHS Letter to Governors.

“……We are seeking to empower states with new opportunities that will strengthen their health insurance markets.”

Thomas E. Price, M.D., The Secretary of Health and Human Services (HHS), A Letter To Governors, dated March 13, 2017

 

On March 13, 2017, the Department of Health and Human Services (HHS) sent a letter to state governors to highlight Section 1332 of the Affordable Care Act (ACA). Beginning in 2017, Section 1332 allows states to apply for a State Innovation Waiver from certain ACA requirements.

With the lawmakers firmly stuck in the healthcare mud, one wonders if some states might start to make health insurance changes on their own. Under a little known provision of the Affordable Care Act (Section 1332) called the State Innovation Waiver, states have the ability to make changes by applying for waivers from certain major provisions of the law beginning this year (2017).  These waivers are intended to allow states the flexibility to pursue innovative strategies for providing their residents with access to high quality, affordable health insurance, while retaining some of the consumer protections of the ACA.

Examples of things that may be waived include:

  • Establishment of qualified health plans (QHPs);
  • Consumer choices and insurance competition through the Exchanges;
  • Premium tax credits and cost-sharing reductions for plans offered within the Exchanges;
  • The employer shared responsibility rules; and
  • The individual mandate.

While this provision and Price’s recent letter on the subject seemingly flew under the radar, you have to wonder if we might start to see some states initiating their own changes to Obamacare. If this is going to happen, we’ll likely start hearing about it in the next few months.  Sometime this summer is when carriers submit rate increases or announce intentions to withdraw from the individual market all together.  Analysts are predicting both to happen.  It’s anticipated carriers will request huge rate increases — sticker shock on steroids — for individual plans on and off exchange.  And, more carriers are expected to be leaving the individual market.  Aetna and UnitedHealthcare are already out, and Bloomberg recently reported that Anthem (BlueCross and Blue Shield in 14 states) is leaning toward exiting in most if not all of its markets.

I doubt anyone really knows where all this is going, or where it will end up. Maybe some states will act, maybe not.

One thing that’s almost certain: Access to employer sponsored health plans will be more important than any time since Obamacare (ACA) became law.

Here’s a link to more info:  HHS Promotes ACA Section 1332 Waivers

It’s Official — Transitional Relief or “Keep Your Plan” for Small Groups Extended Through 2018

The Transitional Relief Provision has been extended as expected at least through December 31, 2018. We reported on it last week here. Small employers with non-ACA compliant or “grandmothered” plans will once again have the option to keep those plans in place until the end of 2018.  Carriers will be notifying policy holders about renewal options in the near future.  BBG clients please contact us anytime if you have any questions or need assistance.

Here is the official CMS release announcing the extension of the Transitional Relief/Keep Your Plan Provision.

MEDICARE PANIC SETTING IN AS EMPLOYEES APPROACH 65th BIRTHDAY??? LET’S CLEAR UP THE CONFUSION ABOUT INITIAL ENROLLMENT

Can’t tell you how many calls and emails we get from panic-stricken employees nearing that magic 65th birthday and Medicare eligibility.  It happens a lot.  A whole lot.

Some folks think if they don’t sign up three months before they turn 65 they’ll be in trouble. Others think the drop dead date to sign up is their birthday.  And, many, many people think if they don’t enroll in Medicare by those dates they either won’t be eligible at all, or they’ll be penalized and get socked with much higher premiums.

Here’s the scoop:

THE MEDICARE INITIAL ENROLLMENT PERIOD IS 7 MONTHS LONG.  IT INCLUDES YOUR BIRTHDAY MONTH, THE 3 MONTHS BEFORE AND THE 3 MONTHS AFTER.

Here are some basics, courtesy of Medicare Made Clear, that employees approaching their 65th birthday may want to know and save them from hitting the panic button:

1.)  You Have a Set Time to Enroll in Medicare

Your Medicare Initial Enrollment Period (IEP) is 7 months long. It includes:

  • The 3 months before the month you turn 65
  • The month you turn 65
  • The 3 months after the month you turn 65

Medicare Enrollment Date Calculator.

2.)  You Can Delay Medicare Part B

Most people get Part A (hospital insurance) premium-free because they or a spouse worked and paid taxes. Part B (medical insurance) has a monthly premium.

You can delay signing up for Part B if you have other health care coverage like employer-sponsored health coverage.  Having employer-sponsored health coverage gives you to the option to delay signing up for Part B, qualifies you for a Special Enrollment Period, and precludes you from getting hit with Late Enrollment Penalties if you elect to delay Part B.

3.)  There Are Two Ways to Get Medicare

Medicare gives you two Medicare Coverage Options:

  • Original Medicare (Parts A & B), the traditional way
  • Medicare Advantage (Part C), an alternative to Original Medicare

Original Medicare is administered by the federal government. Medicare Advantage plans are offered by private insurance companies approved by Medicare. They must provide all the same benefits as Original Medicare Parts A and B. Many plans include additional benefits, such as prescription drug coverage and more.

4.)  Medicare Doesn’t Cover Everything

Original Medicare doesn’t include coverage for prescription drugs. You may buy a standalone Prescription Drug Coverage (Part D) plan to get this coverage.

Some people also buy a Medicare Supplement Insurance (Medigap) plan to help with some costs not paid by Original Medicare.

Generally, you don’t need additional coverage if you choose a Medicare Advantage plan.

 

7 Months. That should make some breathe easier.

UnitedHealthcare News Release Indicates Small Group Transitional Relief Plans (pre-ACA) Are Likely To Be Extended Beyond 2017

While we wait to see what happens with the New Trump Administration’s plans to repeal and replace………….

In a recent field communication pertaining to Small Group renewals, UnitedHealthcare (UHC) announced that they were making provisions for small employers with non-ACA compliant plans to have the option to keep those plans in place beyond 2017. This “Keep Your Plan” option from UHC is contingent upon the Transitional Relief provision being extended again as expected.  Our guess is that some of other carriers in the Small Group market will follow suit.

The Transitional Relief provision was first enacted when the ACA went into full effect in 2014. Often referred to as the “Keep Your Plan” provision, this provision was extended twice after it first went into effect.  Under the last extension all plans not compliant with ACA were set to expire 12/31/2017.

In January, the new Trump Administration issued a memo “to waive, defer, grant exemptions from, or delay the implementation of any provision or requirement of the [ACA] that would impose a…cost…or regulatory burden on individuals, families, [or]…purchasers of health insurance.” UHC’s move indicates they expect the new Administration to issue another “Keep Your Plan” extension and that the expiration date will be postponed for at least another year (through 2018) and perhaps indefinitely.

UHC indicated that the Transitional Relief notice applies to: Arizona, Arkansas, Alabama, Florida, Georgia, Illinois, Iowa, Indiana, Kansas, Kentucky, Louisiana, Michigan, Mississippi, Missouri, Nebraska, North Carolina, Ohio, Oklahoma, Oregon, Pennsylvania, South Carolina, Tennessee, Utah, and Wisconsin.

We’ll be following closely and will keep our clients, especially those who currently have Transitional Relief Plans, posted.

For more info click on the links below:

Trump Administration Aims to Reduce Regulatory Burden

Previous Extension of Transition Policy for Non-ACA Compliant Health Plans Issued 2_29_16

ACA in 2017… Stay Tuned

What do we see?

Our opinion was that if Hillary Clinton had won, ACA would have gotten the heavy lift it would have needed to advance.  The difficult regulations would have been imposed (vs delayed further) and the money would have been allocated from general funds to stabilize the market.

Without the heavy lift, big trouble for ACA would be on the horizon.

The horizon is here.  What we see initially is that the regulations will start to go away (changed or ignored) and cash infusion will not happen.  What remains to be seen is what the party  in power will do to replace the law.  Doing nothing will almost be a replacement, but to what?  The Republicans do have various plans, but which course they will follow remains to be scene.

Our job will be to let you know how this will affect you and your people.  As of today, we just hold the course.  The taxes and reporting requirements are still in place. The plans on the market have not changed.  We will keep you aware as things change. If things hit your radar or you have questions on what you read or hear, please let us know and we will dig in.

For more on the latest:  ACA Compliance Bulletin — Congress Clears Path for ACA Repeal

RECURRING EMPLOYER QUESTION: WHEN ARE THE COSTS OF GROUP TERM LIFE INSURANCE TAXABLE?

Maybe it’s because we’re approaching the end of the year and many are prepping for reporting season.  Whatever the reason, this question about the taxability of Group Term Life Premiums has been asked a few times lately.

So we thought it might be worth posting some info for you.

Here’s the short answer:  Amounts up to $50,000 in coverage are not taxable.  Incremental amounts of coverage above $50,000 in group term life products are taxable based on something called an IRS Premium Table (for more info click on the links below).

In other words, employers can make group-term life insurance coverage available to employees that is in excess of $50,000, but the excess cost of coverage above $50k is taxable to the employee even if employees are paying for the insurance premiums associated with the coverage.

For more detailed information, here’s a link to the IRS page that  discusses Group Life Insurance.

The attached Compliance Overview may also be helpful.   

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