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.
“……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
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- Tom Barrett
- March 31, 2017
- ACA, affordable care act, cost, costs, coverage, deadline, employees, employers, exchange, federal, health plans, healthcare, healthcare reform, HHS, insurance, medical, Obamacare, penalties, ruling
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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.
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- Tom Barrett
- February 24, 2017
- ACA, affordable care act, costs, coverage, employers, federal, health plans, healthcare, healthcare reform, insurance, Obamacare, ruling
- 0 Comments
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
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- Tom Barrett
- February 10, 2017
- ACA, affordable, affordable care act, confusion, cost, costs, coverage, employees, employers, federal, health plans, healthcare, healthcare reform, insurance, Obamacare, states, trends
- 0 Comments