Two Minute Drill

2016 Medical Loss Ratio Rebates: Get a Check From Your Carrier?

Notifications from insurance carriers about this year’s rebates have recently started going out to employers. Under the ACA, carriers have until September 30 to notify employers if they are to receive a rebate.  Any impacted employees will also be notified by the carriers that a rebate is being issued to their employer and that the employee can check with their employer to find out if they qualify for a portion of it.

This is the fourth year of the medical loss ratio rebate checks. While the total number and the aggregate dollar amounts of rebates are about half of what they were in the MLR provision’s first year (2013), more are being issued this year than last year.  From what we hear, a relatively small percentage of employers are receiving rebates and for those that do the amounts are modest.

As a refresher….

The Minimum Medical Loss Ratio (MLR) requirement is part of the Affordable Care Act (ACA). The MLR requirements set minimum percentages of premium dollars that health plans must spend on health care (medical costs and activities that improve health care quality).  If a health plan spends less in medical costs than the minimum percentage it has to pay rebates to employers.  The employer then has to follow government guidelines on how to use the rebates. The employer must use the amount of an MLR rebate that is proportionate to the premiums paid by subscribers (enrolled employees) to benefit its subscribers. There are several ways employers can choose to do this.

For more information you can read our earlier article, refer to 68557 How Employers Should Handle MLR Rebates 8-30-16, or go to

https://www.dol.gov/agencies/ebsa/employers-and-advisers/guidance/technical-releases/11-04

https://www.irs.gov/uac/medical-loss-ratio-mlr-faqs

Example Rebate Check

ARE YOU WONDERING ABOUT THE “CONTROLLED GROUP” QUESTION? HERE’S WHAT YOU NEED TO KNOW

The “Controlled Group” question is popping up for many employers with much greater frequency as part of various and sundry regulatory applications, audits, surveys, reporting requirements and underwriting questionnaires.

Netting it out in layman’s terms — at least as it relates to health insurance and ACA compliance — a controlled group may exist when multiple companies fall under common ownership.

The ACA includes a provision under which companies that have a common owner (or are otherwise generally related) are combined and treated as a single employer for purposes of determining if the companies collectively employ at least 50 FTEs (the combo of full-time EEs and full-time equivalent EEs).

THE LAW OF DISPROPORTIONATE COSTS: SMALL NUMBER OF EMPLOYEES ACCOUNT FOR LION’S SHARE OF GROUP HEALTH PLAN MEDICAL COSTS

There’s plenty of cost related analytics available to support the disproportionate cost premise that medical expenses are highly concentrated among a very small proportion of enrolled employees.  These highlights, for example, from a Agency for Healthcare Research and Policy (AHRQ) are pretty telling:

  • 1 % of the population accounts for 21.4 % of total health care expenditures nationally
  • 5 % of the population account for 49.9 % of total expenditures
  • 10 % of accounts for 65.6 % of all medical costs

EMPLOYER REIMBURSEMENT OF INDIVIDUAL HEALTHPLAN PREMIUMS REMAINS A BANNED PRACTICE UNDER ACA

While this was more of a hot topic when the full monty of healthcare reform was implemented back in 2014, some employers perhaps unaware of the turmoil in the individual marketplace still ask about reimbursing employees for individual health insurance policies.

The IRS, the Department of Labor and Health and Human Services have all released several directives and guidelines that pretty clearly prohibit the practice. The most recent was issued in December 2015 (n-15-17).

Definition of Predicament: People Who Don’t Have Access to Employer Coverage, Aren’t Medicare Eligible, and Don’t Qualify for Subsidies

Yes, this is a bit anecdotal. Nevertheless, I think it’s  worth reporting and some may find it interesting.

First, recently our team managed the annual open enrollment process for the group health plan of one of our employer clients. After a quick but thoughtful evaluation of options, one employee who was previously covered by an individual market policy opted to enroll on the employer’s group plan (family coverage) and terminate coverage under the individual market plan. Both the individual plan and the group plan were Qualified Health Plans (QHP) under ACA. The plans had similar benefits. And, they were underwritten by the same large insurance carrier.

Savings?

$600 a month in gross premium. That’s quite a spread.  Add in the employer contribution and the savings to the employee were even greater.

The HHS Move to Curtail the Availability of Short Term Health Coverage Will Hurt Consumers In Need of an Affordable Bridge To Other Coverage……

………Like Medicare or Other Employer-Sponsored Coverage.

Yesterday the Obama Administration and HHS announced they were significantly curtailing the availability and use of short-term health insurance.

Their reasons? Not exactly sure.

Maybe it’s due to the myriad of current issues in the individual market – rising rates, carriers pulling out, and actuarially not enough covered lives (especially healthy people) – and the need to get more healthy people to buy individual policies. Take away options and hopefully it’ll drive more people to buy on the exchange.

Maybe, it’s a shot at UnitedHealthcare (UHC is one of the main providers of short –term or temporary coverage). Retribution, possibly, for UHC pulling out of the exchanges?

Ohio’s Health Co-op (In-Health) Shut Down

In-Health, the Ohio health insurance Co-op established as a part of ACA, is shutting down.  Here’s an explanation of the co-op program. HCR Consumer Operated and Orientated Plan CO OP Program.

Although no BBG client is insured by In-Health, we wanted to let you know in case it hits your radar with employees that get their insurance from a source other than your employer sponsored plan.

In-Health insured approximately 23,000 Ohioans.
We will help anyone who needs it.

In the meantime,

Things to know:
– Claims are to be paid (according to the Ohio Department of Insurance)
– Members will be informed of how the run-down will work
– In the near future the members will need to shop for new insurance and will be provided an special open enrollment period

We hope this does not affect any of your people, but if it does feel free to let us know. We will help.

You can read more about the implications of InHealth’s shut down here.

“Dear Employer” Letter from Medicare (Part 2) – Compliance Overview

The CMS Data Match program determines whether an employer-sponsored group health plan has the responsibility for paying health care claims before Medicare. As discussed in last week’s post, with the number of workers age 65 and over steadily increasing, many employers are receiving letters from CMS asking for information about their employer-sponsored health coverage.  Employers are required to respond or be subject to penalties (fines).  This Compliance Overview summarizes these requests for information and highlights the corresponding steps for responding………………Medicare Secondary Payer IRS SSA CMS Data Match.

Medicare Secondary Payer IRS SSA CMS Data Match

 

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