ruling

Deja Vu: CMS extends Transitional Relief Plans (pre-ACA) Through 2019

The Centers for Medicare and Medicaid (CMS) recently announced that employers in the small group market that are currently still enrolled in Transitional Relief Plans (also known alternatively as Keep Your Plan, Grandmothered Plan, Pre-ACA Plan, etc.,) may keep their existing policies and plans for another year.  

CMS stipulates that ultimately granting the extension is left to the discretion of state regulators and to the respective participating insurance carriers. Most — if not all – states and carriers are expected to grant the extensions and allow employers to keep the Transitional Relief Plans in place for another year.

The CMS announcement also noted that the Transitional Relief Plans will not be considered out of compliance.

This extension, first granted in 2014 and granted every year since, runs through December 31, 2019.

We’ll be following this closely with the insurance carriers and will keep all of our clients who currently have Transitional Relief Plans informed.

For more info click on the link below:

CMS_Extension-Transitional-Policy-Through-CY2019

Executive Order Ends the “Out-of-Pocket” Subsidy Only; the “Premium” Subsidy Remains in Place

Some folks may think that Friday’s Executive Order did away with Obamacare subsidies altogether.  It didn’t.

There are two subsidies. One was cut.  One wasn’t.

In a nutshell, one subsidy lowers the cost of premium (aka premium tax credits) for those qualified individuals and families enrolled through the exchange and making less than 400% above the poverty level.  This stays in place.

The other covers a reduction in the out-of- pocket expenses or claims costs paid to the medical provider by the patient (aka cost-sharing reductions). This subsidy applies to those earning below 250% of the poverty level and covered by a plan issued by the insurance company through the exchange.

It’s this out-of-pocket budget appropriation that was cut by Friday’s Executive Order.

From what we hear, despite Friday’s Order most of those enrollees who qualify for the out-of-pocket assistance will continue to receive it as part of their coverage at least through 2018.  Many of the insurance carriers still participating on the exchange expected the subsidy cut and planned for it when they filed their rate increases and established their pricing for 2018.

You can read more here.

The Check’s in the Mail — MLR Premium Rebate Checks and What Do We Do with Them

Some BBG employer clients are reporting that they have received MLR rebate checks from their carrier.

What are MLR rebate checks and why do only some employers receive them?

Affordable Care Act rules stipulate that insurance carriers must spend a certain percentage of health insurance premiums on medical claims and other specified related activities. This is referred to as a Medical Loss Ratio (MLR).

The MLR ratio for small groups is 80/20, For large groups it’s 85/15.

If an insurance company spends less than the MLR amount designated by Obamacare then the insurance company must rebate the unspent portion back to the employer sponsoring the plan.

Wondering what to do if you are one of those employers receiving an MLR rebate check?

There are rules established by the Department of Labor governing distribution. Employers must use these as guide when allocating and distributing the rebate dollars. The rules can be found here http://dol.gov/ebsa/newsroom/tr11-04.html.

In a nutshell:

Employer groups are required to treat the rebate as a plan asset.  Uses may include, but are not limited to, reducing future premiums or premium increases, or rebating a portion back to the subscribers.  The rebate is required to be used for the benefit of the subscribers in one of the following ways:

• To reduce subscribers’ portion of the annual premium for the subsequent policy year for all subscribers covered under any group health policy offered by the plan;
• To reduce subscribers’ portion of the annual premium for the subsequent policy year for only those
subscribers covered by the group health policy on which the rebate was based; or
• To provide a cash refund only to the subscribers who were covered by the group health policy on which the rebate is based.

A more thorough review of what to do with MLR Rebate Checks can be found by clicking here How Employers Should Handle MLR Rebates

Clients can contact BBG for assistance.

Example Rebate Check

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 .

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