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Health plans - design


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[Official Guidance] Text of DOL, HHS and IRS Proposed Regs: Amendments to Excepted Benefits
"After consideration of comments on the 2013 proposed regulations, the Departments are publishing these proposed regulations to address limited wraparound coverage and solicit comment before promulgation of final regulations on limited wraparound benefits.... These proposed regulations seek comment on two options for limited wraparound coverage to be considered an excepted benefit. The Departments intend that, after notice and comment, one or both options could be finalized. (That is, they are not necessarily alternatives and, therefore, could be implemented side by side). The regulations include a sunset date and, therefore, would operate as a pilot program. While some elements of this proposal are the same as those in the previous proposal, this new proposal contains changes in response to suggestions and adds new elements for reporting and data collection to gather information to inform future rulemaking.... These proposed regulations set forth five requirements under which limited benefits provided through a group health plan that wrap around either eligible individual insurance or coverage under a Multi-State Plan (limited wrap around coverage) constitute excepted benefit ... [1] Covers additional benefits ... [2] Limited in amount ... [3] Nondiscrimination ... [4] Plan eligibility requirement ... [5] Reporting." (Employee Benefits Security Administration [EBSA], U.S. Department of Labor; Internal Revenue Service [IRS]; and U.S. Department of Health and Human Services [HHS])
How Responsive Are Millennial Employees to Your Wellness Efforts?
"Millennials are the least likely to participate in activities focused on prevention and maintaining or improving physical health compared to other generations. About half (54 percent) have had a physical in the last 12 months, compared to 60 percent of Generation X and 73 percent of Baby Boomers.... More than half (52 percent) say 'living or working in a healthy environment' is influential to their personal health, compared to 42 percent of Generation X and 35 percent of Baby Boomers. Millennials also are more open to having their direct manager play an active role in encouraging them to get and stay healthy (53 percent), compared to 47 percent of Generation X and 41 percent of Baby Boomers[.]" (Wolters Kluwer Law & Business)
[Official Guidance] Text of CMS Draft 2016 Letter to Issuers in the Federally-facilitated Marketplaces and SHOPs (PDF)
59 pages. "This Letter provides issuers seeking to offer qualified health plans (QHPs), including stand-alone dental plans (SADPs), in the Federally-facilitated Marketplaces (FFMs) or the Federally-facilitated Small Business Health Options Programs (FF-SHOPs) with operational and technical guidance to help them success fully participate in those Marketplaces in 2016. Unless otherwise specified, references to the FFMs include the FF-SHOPs. Throughout this Letter, CMS identifies the areas in which states performing plan management functions in the FFMs have flexibility to follow an approach different from that articulated in this guidance. CMS notes that the policies articulated in this Letter apply to the certification process for plan years beginning in 2016." (Centers for Medicare & Medicaid Services [CMS], U.S. Department of Health and Human Services [HHS])
The Year in Exchanges: Where Private Exchanges Go from Here
"[T]he majority of employers are still waiting to see evidence of what value private exchanges provide, but more importantly, are waiting for someone else in their market to make the jump first, says Jean Moore, managing director of Towers Watson Active Exchange. According to Moore, 34% of employers are waiting for someone else to switch. Once that happens, she expects others will follow right away -- even before data about the move comes in." (Employee Benefit Adviser)
Active and Retired Public Employees' Health Insurance: Potential Data Sources
"Employer-provided health insurance for public sector workers is a significant public policy issue. Underfunding and the growing costs of benefits may hinder the fiscal solvency of state and local governments. Findings from the private sector may not be applicable because many public sector workers are covered by union contracts or salary schedules and often benefit modifications require changes in legislation. Research has been limited by the difficulty in obtaining sufficiently large and representative data on public sector employees. This article highlights data sources researchers might utilize to investigate topics concerning health insurance for active and retired public sector employees." (Journal of Health Economics; purchase required)
Regence BlueShield Bets on 'Accountable Health' Group Plans
"One Blue insurer will find out just how much employer appetite there is for health plans with limited but transparent networks branded as both accountable and affordable. Washington State's Regence BlueShield, one of the four Blues insurers in the Cambia Health Solutions family, is introducing ActiveCare, a new group health plan offering built on accountable care partnership with four providers that form network choices.... Members enrolled in the ActiveCare plans choose a primary care physician from the affiliated provider system, and those primary care doctors then are tasked with coordinating healthcare needs and overseeing referrals within the parent organization." (Healthcare Payer News)
[Guidance Overview] What Will 2015 Hold for the ACA and Employers?
"Despite the detailed discussion of the lookback measurement and method in the final rule, a number of questions and ambiguities remain.... Although the use of the lookback approach is complicated and administratively burdensome, it does afford more flexibility and certainty than a strict monthly calculation. Looking ahead to 2015, the questions and challenges regarding determination of full-time employee status are likely to grow. Although additional guidance from the IRS may be forthcoming, employers will enter the new year with compliance challenges ahead." (Littler)
Vermont Abandons Single Payer, for Now
"Three years after Vermont's legislature passed Act 48 creating a roadmap for a state-financed single payer system called Green Mountain Care, Governor Peter Shumlin has abandoned the idea ... A team within the Shumlin Administration had drafted a financing proposal to fund Green Mountain Care, a public healthcare plan envisioned to cover 94 percent of healthcare costs for all Vermonters except those enrolled in Medicaid or Tricare. The proposal called for an 11.5 percent payroll tax on all businesses, as well as a 9.5 percent assessment on individuals earning over 400 percent of the poverty level, with a lower, sliding scale tax for those earning under 400 percent FPL." (Healthcare Payer News)
[Official Guidance] Text of CMS Quality Rating System (QRS) Frequently Asked Questions (FAQs) (PDF)
FAQs include: "[1] If a [Qualified Health Plan (QHP)] issuer offers multiple products (e.g., EPO, HMO, POS, PPO) in the Marketplace, can products be combined for the Quality Rating System (QRS) and the QHP Enrollee Experience Survey (QHP Enrollee Survey) reporting? [2] Do the [QRS] and the QHP Enrollee Experience Survey requirements only apply to QHP issuers participating in State-based Marketplaces (SBMs)? [3] What are the deadlines for QHP issuers to contract with data validators and survey vendors in preparation for [QRS]) and the QHP Enrollee Experience Survey data submission? Are these deadlines flexible? [4] Will CMS accept state-mandated quality measure data to meet [QRS] requirements?" [Dated November 16, 2014; published online December 17, 2014.] (Centers for Medicare & Medicaid Services [CMS], U.S. Department of Health and Human Services [HHS])
Without Direct Employer Action, Alternate Health Care Delivery Models and Payment Reform May Stall at Current Levels
"[W]hile employers find alternative provider delivery models and payment reform attractive, most admit they do not understand them or the value they provide. As a result, they may miss a significant opportunity to lead and improve results (health and financial) for their workforce and business.... Despite their lack of understanding of the models, the survey showed 60 percent of companies are providing or are considering providing a financial incentive for employees and dependents to use these new models through plan design changes, narrow network options, HRA/HSA contributions or cash." (Aon Hewitt)
[Guidance Overview] Probationary Periods: ACA and California Law are Back in Sync (SB 1034)
"Senate Bill 1034 becomes effective January 1, 2015 and repeals the 60-day waiting period limit previously imposed on certain health insurance plans in California. Now employers can go back to the 90-day probationary period with benefits as a reward to employees who 'pass' probation. This comes just in time for the year-end employee handbook updates." (Fox Rothschild LLP)
Public Easily Swayed on Attitudes About Health Law
"Six in 10 respondents to the monthly tracking poll from the Kaiser Family Foundation ... said they generally favor the requirement that firms with more than 100 workers pay a fine if they do not offer workers coverage. But minimal follow-up information can have a major effect on their viewpoint, the poll found. For example, when people who support the 'employer mandate' were told that employers might respond to the requirement by moving workers from full-time to part time, support dropped from 60 percent to 27 percent. And when people who disapprove of the policy were told that most large employers will not be affected because they already provide insurance, support surged to 76 percent." (Kaiser Health News)
The Dark Side to Uncontrolled Drug Benefits
"Obviously, plan sponsors have financial reasons for steering people toward a generic drug instead of a more expensive (and possibly heavily marketed) brand-name drug. Or for limiting how much of a costly drug people can get at one time. However, putting controls on access to prescription drugs can be healthier for plan participants, benefiting them far more than it might hurt them[.]" (International Foundation of Employee Benefit Plans [IFEBP])
Critics Challenge Corporate Wellness Program ROI
"Even with the modest rise in health care costs over the past several years, sources familiar with the issue believe businesses have reached a tipping point and that the expense of providing medical benefits to workers has become unsustainable. Cost-containment efforts therefore are putting more pressure on wellness programs to deliver on the promise of reducing health care expenses. However, as ... recent studies have shown, wellness plans may not be producing the return on investment (ROI) that employers expect and need." (Society for Human Resource Management [SHRM])
[Guidance Overview] Reference-Based Pricing and the ACA's Rules on Out-of-Pocket Limits
"Plan sponsors of non-grandfathered plans that have or are considering a reference-based pricing program must review the program to ensure that it complies with several factors related to quality and access. The Departments will consider all the facts and circumstances when evaluating whether a plan is using a reasonable method to ensure adequate access to quality providers at the reference price, including the following: Type of Service ... Reasonable Access ... Quality Standards ... Exception Process ... Disclosure ... It is likely that existing programs will not fully comply with these new rules, particularly some of the participant disclosure and exception process rules, and will need to be revised." (Segal Consulting)
[Guidance Overview] 2014 Plan Sponsor ACA and Year-End Checklist (PDF)
12 pages. "2014 has been another busy year of regulations and guidance affecting health and welfare benefit plans.... Many of the rules and regulations went into effect in 2014, while others were issued in 2014 but will not be effective until 2015 or later.... To help you ensure that nothing slips through the cracks, [this article provides] the highlights for 2014." (Alston & Bird LLP)
Class Action Suits Mounting for ERISA Plan Clawbacks
"A fractious and potentially costly family of provider-led class action lawsuits [is] moving through courts, pitting accusations of illegal clawbacks against the likes of Aetna and UnitedHealth Group. In New Jersey, a federal judge has certified a class of providers suing UnitedHealth Group for allegedly illegal payment recoupments under ERISA... Similar to complaints against other insurers, the providers suing UnitedHealth allege that the insurer conducted post-payment audits, concluded that it made erroneous overpayments, and then demanded to be repaid[.]" (Healthcare Payer News)
[Guidance Overview] Being Proactive v. Reactive: ACA's Prohibition on Discrimination in Group Health Insurance
"[T]he IRS has informally indicated that an extension of eligibility to former employees who are [highly compensated individuals (HCIs)] would raise an eligibility discrimination issue, and all former employees should be considered in the test....If the IRS does not change its position when it issues new guidance, ... all former employees will need to be aggregated and tested in a group distinct from active employees. Thus, if the group of former employees extended continued coverage benefits all or mostly HCIs, it will not pass the eligibility test....[If] an insured plan is determined to be discriminatory, the penalty for the employer would be much more severe than the penalty for a discriminatory self-funded plan." (Benefits Bryan Cave)
ACA Cadillac Tax: Essential Issue for 2015 Labor Contract Negotiations
"The Cadillac tax has been recently described as more of a 'Camry' or 'Chevy' tax.... [E]ven ACA-silver tier plans, depending on geographic location, could be subject to the excise tax soon after 2018 due to the tax's thresholds being tied to the general CPI-U, rather than the faster increasing index of health care costs. According to a recent Towers Watson survey, 54% of employer plans will trigger the excise tax by 2020 if current health care benefit strategies remain unchanged.... Employers who will be negotiating new three year contracts in 2015 do not have the luxury of deferring consideration of this issue as the Cadillac tax will begin before the expiration date on such contracts." (Clifton Budd & DeMaria, LLP)
Findings from the SHRM/EBRI 2014 Health Benefits Survey (PDF)
"[O]nly 1 percent of plan sponsors are planning to eliminate health benefits in 2015.... A relatively large number of employers continue to introduce wellness rewards and penalties ... Few employers are planning to make changes to eligibility for spousal coverage and part-time worker benefits, and few are moving toward tiered networks, private health insurance exchanges, value-based insurance design, and reference pricing." (Employee Benefit Research Institute [EBRI])
[Guidance Overview] CRomnibus includes 'Expatriate Health Coverage Clarification Act' (PDF)
"The CRomnibus provides a permanent statutory exemption from most of the ACA's requirements for statutorily-defined 'expatriate health plans.'... Expatriate health plans now officially qualify as an eligible employer-sponsored plan that is minimum essential coverage. This means that an expatriate health plan will satisfy the enrollee's individual mandate.... [T]he exemption does not apply for the new health information reporting requirements for the beginning of 2016." (ABD Employee Benefits)
[Guidance Overview] Guidance on Reimbursing Individual Health Insurance Premiums and Offering High-Risk Employees a Choice Between Enrollment and Cash
"In some circumstances, it is acceptable to provide more favorable treatment based on a health factor, a practice known as benign discrimination. For example, some plans allow disabled dependents to remain covered past age 26. However, the Departments state that offering cash in lieu of coverage only to employees with high medical claims risk is not a permissible form of benign discrimination under the HIPAA rules." (Sibson Consulting)
The 2015 ABC's of Employee Benefits, Part 2
"From ERISA 510 to skinny plans and private health care exchanges, the ABC's of employee benefits outlines the issues benefit decision-makers need to be aware of in the coming year." (Ed Bray, in Employee Benefit News)
[Guidance Overview] Individual Mandate Regs Address Affordability, and Here's Why Employers May Care
"If employer-sponsored coverage is unaffordable, and the employee does not enroll in it, then the employee may be eligible for a premium tax credit for ACA Marketplace/Exchange coverage. Receiving that tax credit could trigger a play or pay penalty for the employer. We say 'could' because the employer play or pay regulations do have safe harbors for determining affordability[.]" (Benefits Bryan Cave)
EEOC Cracking Down on Workplace Wellness Programs
"It seems unlikely, given the lawsuits brought to date, that the EEOC would spend finite resources attacking wellness programs designed so that the premium differential is not dependent on medical examinations or completion of HRAs. However, most employers have routinely rejected such wellness programs as failing to provide sufficient return on investment. Will the EEOC continue to challenge more typical wellness programs where failure to participate only triggers penalties in the 30-50% range specifically permitted under HIPAA and PPACA? ... Is there a direct correlation between the amount of the financial impact to the employee and the risk of a lawsuit being brought by the EEOC?" (Warner Norcross & Judd LLP)
Small Businesses Drop Coverage as ACA Offers Alternatives
"Companies ... with fewer than 50 workers ... provide medical coverage to roughly 20 million people. Unlike larger employers, they have no obligation under the health law to offer a plan. Now they often have good reason not to.... Anthem, the largest seller of small-business health insurance, lost almost 300,000 members in such plans -- many more than expected -- in the first nine months of the year. That was 15 percent of the enrollment." (Kaiser Health News)
U.S. Corporate Health Exchanges Find No New Blue Chip Clients
"By last year, blue chip names like Sears Holding and Walgreen Co had signed on and industry experts predicted that more than 20 percent of the nation's employees would soon buy their health insurance in this way, compared with less than 2 percent today. But Reuters interviews with nearly a dozen industry executives has found that no major U.S. company signed up their employees for the first time to a private health insurance exchange for 2015. Many of those executives expect a similar situation in 2016, as blue chip employers wait for proof that the new exchanges will save them enough money to warrant the switch, raising doubts about this new business model." (Reuters)
[Guidance Overview] Evolution of the Health Plan Coverage Mandates Continues
"Because the current edition of the DSM recognizes the diagnosis of gender dysphoria for person whose gender at birth is contrary to the one with which they identify as a mental disorder, New York is mandating that insurers issuing policies in New York use the 'DSM as the recognized independent standard of current medical practice in determining what constitutes a mental health condition.' ... Employers providing group health plan coverage outside of New York that are subject to the MHPAEA should watch for additional developments in this area, including the new requirements applicable to federal contractors described [in this article]." (Winstead PC)
41% of Employers Considering Private Health Insurance Exchange for Benefits Delivery by 2018, 6.4% Have Already Implemented (PDF)
"The Private Exchange Evaluation Collaborative (PEEC) is an initiative launched by four leading nonprofit business coalitions (Employers Health Coalition, Midwest Business Group on Health, Northeast Business Group on Health, and Pacific Business Group on Health) and PwC.... The survey is intended to help employers understand how their peers are thinking about private exchanges, their timelines for consideration and what features they view as critical, and to highlight what types of information about private exchanges are most important to employers." (The Private Exchange Evaluation Collaborative [PEEC])
The 2015 ABC's of Employee Benefits (A-M)
"Given the tremendous amount of activity and volatility in the employee benefits space, 2015's version of EBN's annual benefits ABC's can be summed up in one sentence: Surround yourself with quality, interested and engaged help or else it will be a very long and painful year." (Ed Bray, in Employee Benefit News)
Bogged-Down Global Benefit Managers Are Missing Opportunities
"Nearly two-thirds (62%) of global pension and benefit managers claim that day-to-day operational activities are limiting their ability to add value and hampering their strategic contribution to the company ... [T]hree-quarters (75%) of [survey] participants also feel that there is increasing pressure for them to do more with less, suggesting they are going to have to change the way they do things if they are to create the time to focus on more value added activities." (Towers Watson)
Where Employers Use Quality Control to Shape Healthcare
"Most businesses ... are reluctant to manage medical providers as they might other key suppliers. It's different on Puget Sound. Boeing and other major employers here, including Starbucks and Costco, have aggressively pushed local hospitals and doctors to meet the kinds of rigorous standards they use to build airplanes or brew coffee. That has nurtured an unusual relationship between employers and medical centers that has affected the way patients are treated for back pain, how they are counseled for depression, even how they schedule doctors' appointments." (Los Angeles Times)
[Guidance Overview] Beneath the Hood of the 'Cromnibus'
"Section 227 of Cromnibus provides that CMS may not transfer other funds from other accounts to pay for the risk corridor program. The CMS program appropriation section, however, does appropriate user fees, which can therefore be used to fund the risk corridor program. Expenditures on the program, however, cannot exceed the funds collected.... A second provision ... provides that if expatriate plans meet certain basic requirements they will qualify as 'minimum essential coverage' for purposes of the individual mandate.... A third provision ... redefines the medical loss ratio requirement applied to Blue Cross/Blue Shield (BCBS) plans ... Cromnibus requires CMS to detail in its 2016 budget all funds that have been spent since the enactment of the ACA and what spending is anticipated for 2016 on a list of activities specified." (Timothy Jost, in Health Affairs)
2014 Report to Congress: Compliance with the Mental Health Parity and Addiction Equity Act of 2008
"This second report to Congress updates DOL's initial findings and outlines the next steps under consideration for continued implementation and enforcement of MHPAEA. Since the submission of the initial report, major developments in the MHPAEA infrastructure include the completion of the MHPAEA compliance study and the promulgation of the final rules.... This report provides an overview of these developments and highlights the ongoing efforts being taken in the context of the previously established MHPAEA implementation framework to ensure that parity is accomplished as intended by the law." (Employee Benefits Security Administration [EBSA], U.S. Department of Labor [DOL])
[Official Guidance] Text of OPM Proposed Regs: Federal Employees Health Benefits Program Plan Performance Assessment System
"To establish a consistent assessment system, create a more objective performance standard, and provide more transparency for enrollees, OPM is developing a framework that will utilize a discrete set of quantifiable measures examining key aspects of contract performance and specific criteria for performance factors which will then be linked to health plan premium disbursements. This regulation proposes to replace the current methods of plan assessment with a new framework, in which both experience-rated and community-rated plans utilize the same measurement criteria." (Office of Personnel Management [OPM])
[Guidance Overview] ACA Resources for Frequently Asked Questions, Updated December 10, 2014 (PDF)
20 pages. "The report provides basic consumer sources, including a glossary of health coverage terms. The next sections focus on health coverage: the individual mandate, private health insurance, and exchanges, as well as public health care programs ... It then lists sources on employer-sponsored coverage, including sources on employer penalties, small businesses, federal workers' health plans, and union health plans. It also provides sources on the ACA's provisions on mental health, public health, workforce, quality, and taxes. Finally, the report lists sources on ACA costs and appropriations, legal issues, the treatment of noncitizens under the ACA, and sources for obtaining the law's full text." (Congressional Research Service [CRS])
Health Plan Renewal Delays Skyrocket
"Delaying health plan renewals appears to be the new normal under the [ACA], especially for small businesses. The number of such delays expected through December 1 soared 322% within the past year, while 94% of the 32% of respondents reporting this action were small firms with 100 or fewer employees. Many of them face rate increases ranging from 30% to 160% in states that did not allow renewal of grandfathered health plans[.]" (Employee Benefit Adviser)
Many Obamacare Plans Set Out-of-Pocket Spending Limits Below the Cap
"Seventy-four percent of 2015 silver level plans' out-of-pocket spending caps are below the $6,600 spending limit allowed for individual plans and $13,200 maximum for family plans ... The average out-of-pocket maximum for 2015 individual silver plans will be $5,853 ... Silver was the most popular plan type this year, selected by about two-thirds of enrollees." (Kaiser Health News)
[Official Guidance] Text of OPM Request for Applications: Multi-State Plan Program Advisory Board
" Applications will be accepted until February 16, 2015.... Members of the Advisory Board shall exchange information, ideas, and recommendations regarding OPM's administration of the [Multi-State Plan (MSP)] Program, including plan design, branding and marketing, network adequacy, and other topics ... This forum will serve to better inform OPM's policy development, rulemaking, and outreach activities with regard to the MSP Program.... A significant percentage of the Advisory Board members should be MSP Program enrollees or MSP Program enrollee representatives. Enrollee representatives may include public health and/or healthcare professionals (including providers, navigators, and assisters) or members of other consumer advocacy groups that have worked with or on behalf of healthcare consumers. Health insurance issuers or representatives of health insurance issuers will not be considered for Advisory Board membership." (Office of Personnel Management [OPM])
[Official Guidance] Text of IRS Publication 15-B: Employer's Tax Guide to Fringe Benefits for Use in 2015 (PDF)
31 pages. "What's New: Cents-per-mile rule.... Qualified parking exclusion and commuter transportation benefit.... Qualified parking exclusion and commuter transportation benefit.... Contribution limit on a health flexible spending arrangement (FSA) ... Additional permitted election changes for health coverage under a cafeteria plan ... Reminders: Same-sex Marriage ... 'Use-or-lose' rule for health FSAs ... Additional Medicare Tax withholding." (Internal Revenue Service [IRS])
How 'Cromnibus' Helps Blue Cross and Blue Shield But Not Other Insurers
"Many of the nonprofit 'Blue' health plans receive tax breaks on their expenses and reserves as part of a 1980s arrangement in which they lost their broader tax-exempt status. Under the 2010 health law, Blue plans had to spend at least 85% of their revenue from insurance premiums on medical claims to continue to qualify for the breaks. The provision in the 'cromnibus' bill ... would let the Blue plans count spending on improving health-care quality toward the 85% threshold." (The Wall Street Journal; subscription may be required)
[Guidance Overview] New ACA Affordability Rules Impact Cafeteria Plan Flex Credits
"[E]mployers may need to designate a portion of the total flex credit amount that may only be spent on benefits providing medical care (such as medical, dental, vision and health FSA) in order to be able to count the flex credit in the affordability calculation, including application of the affordability safe harbors under the Code 4980H regulations.... This final rule may have an even broader impact on employers that vary an employee's rate of pay based on enrollment in benefits, plans with cash waiver credits or opt-out payments, and those plans that provide cash in lieu of benefits to employees covered by the McNamara-O'Hara Service Contract Act (SCA)." (Hill, Chesson & Woody)
[Guidance Overview] ACA Compliance Check for Community Colleges
"California community college districts are in the process of finalizing safe harbors and measuring hours. However, there is more to the ACA than tracking hours of employees. In order to avoid potential penalties, community college districts should use this checklist to ensure they are not overlooking other important aspects of the ACA." (Liebert Cassidy Whitmore)
Why a National High-Risk Insurance Pool Is Not a Workable Alternative to the Marketplace
"This issue brief draws on the PCIP experience to outline why national high-risk pools, which continue to be proposed as policy alternatives to ACA coverage expansions, are expensive to enrollees as well as their administrators and ultimately unsustainable. The key lesson -- and the principle on which the ACA is built -- is that insurance works best when risk is evenly spread across a broad population." (The Commonwealth Fund)
Value-Based Payment Is Spreading, But Models Need Refinement
"Some 40 percent of payments by private plans to health care providers are now tied to 'value,' meaning they are linked to better or less costly care, rather than the volume of services provided. In 2013, just 11 percent of such payments aimed to improve quality and efficiency." (The Commonwealth Fund)
Young Invincibles Want to Pay for Low-Deductible Plans
"In a [recent survey], more than 50 percent of those earning at least $50,000 said they would rather buy a health plan with a low premium and a high deductible -- something that less that 40 percent of those earning less than $50,000 would prefer.... Forty-six percent of Millennials ... said they'd prefer to buy a coverage plan with high premiums and low deductibles, compared to only 33 percent of those 50 or older." (Healthcare Payer News)
Year-End Employee Benefits and Compensation Planning Ideas (PDF)
5 pages. "December may be the last time to take some actions in order to be effective in 2015, such as nonqualified plan salary deferral elections, while in other cases December provides a new opportunity to ensure arrangements are ready for new rules in 2015, such as the [ACA] employer mandate. [This article provides a] list of key considerations for the end of 2014 and the beginning of 2015." (PricewaterhouseCoopers)
EEOC Targets Voluntariness of Employer-Sponsored Wellness Programs
"[A table in this article] summarizes certain facts related to the wellness programs at issue. The employee incentives involved in these cases are significant; employees who elect to forgo participation in the programs lose 'incentives' such as eligibility for health insurance coverage or 100% employer-paid premiums.... Although it is clear from the complaints that the EEOC believes the penalties at issue render the wellness programs involuntary, the complaints do not shed much light on the threshold at which an incentive is deemed a penalty that renders a wellness program involuntary." (Bass, Berry & Sims)
What to Watch for During This Year's Open Enrollment Period: Lessons from the Health Reform Monitoring Survey
"While increasing awareness of the Marketplace will continue to be important as the second open enrollment period unfolds, there are two additional issues that may determine how many more uninsured people actually gain coverage this year. First, will the remaining uninsured be reluctant to seek coverage and enroll during the current open enrollment period, and if so, why? Second, for people seeking information on health plans, what sources of information are they likely to turn to, and will those sources be adequate to meet the demand?" (Health Affairs)
Economics of Health Insurance Exchanges
Page includes summaries of and links to working drafts of papers presented at a meeting held December 5, 2014, and chaired by Leemore Dafny, Northwestern University, and Jonathan Gruber, MIT: [1] Measuring Consumer Valuation of Limited Provider Networks; [2] Controlling Health Care Costs Through Limited Network Insurance Plans: Evidence from Massachusetts State Employees; [3] The Effect of Market Size and Composition on Health Insurance Premiums: Evidence from the First Year of the ACA; and [4] Competing under New Rules of the Game: An Analysis of Insurer Entry and Premiums for Exchange-Based Coverage. (National Bureau of Economic Research [NBER])
Managing the Impact of Long-Term Care Needs and Expense on Retirement Security
"The collection of papers in this monograph were the result of a call for papers issued by the SOA's Committee on Post Retirement Needs and Risks in partnership with the Long Term Care Section to explore the impact of long-term care needs and expense on retirement security from a variety of aspects." [Page includes links to 12 papers, as well as an Overview Chapter and Collected Abstracts.] (Society of Actuaries)
[Official Guidance] Text of DOL Submission to OMB with Comment Request: Revisions to Coverage of Certain Preventive Services Under the ACA (PDF)
"[EBSA] is soliciting comments on the revision of the Coverage of Certain Preventive Services Under the Affordable Care Act information collection to reflect the new option of notifying [HHS] of the respondents' objections to providing coverage in response to the Supreme Court of the United States' interim order in connection with an application for an injunction in the pending case of Wheaton College v. Burwell.... No change to the existing ICR is proposed or made at this time." (Employee Benefits Security Administration [EBSA], U.S. Department of Labor)
Health Savings Accounts for Retirement: Maximizing Retirement Savings Options
"HSA enrollments have grown substantially since their inception in 2004, more than doubling in the last 5 years, and are expected to reach almost $25 billion by year-end 2014, and $40 billion by 2016.... Many HSA providers have investment options available for participants, ranging from a set menu of mutual funds, to a self-directed brokerage window. As balances continue to grow, and more participants build up sufficient funds to cover their maximum out-of-pocket exposure under their high deductible health plans, this trend is also expected to continue." (Manning & Napier)
[Guidance Overview] Healthcare Reform Transparency Requirements Again Delayed
"The [ACA] requires [HHS] to establish criteria for certification of insurers' health plans as 'qualified health plans' eligible to be sold on the exchanges, including marketing requirements, ensuring sufficient choice of providers, implementing quality improvement and using uniform enrollment forms and formats for presenting health plan options.... Although cost-sharing data were included on the Internet as part of the comparison of plan options available during last year's open-enrollment period, HHS still has not published rules for the nine categories of consumer protection coverage data set out in Section 1311(e)(3). The delay in enforcement reflects the greater complexity of the coverage data and the corresponding challenges in developing disclosure rules." (McGuireWoods LLP)
Obamacare CO-OPs Cut Prices, Turn Up Heat on Rival Insurers
"HealthyCT, which cut its 2015 premiums by an average of 8.5 percent, is one of at least a half dozen co-ops created through the [ACA] that have lowered 2015 premiums in a bid to boost membership in their second year of operation. But those low premiums are upsetting so-called 'legacy' insurance plans like Blue Cross and Blue Shield affiliates that have traditionally dominated insurance markets." (Kaiser Health News)
Will More Small Firms Self-Fund Their Healthcare Plans?
"The [ACA] was intended to increase access to quality and reliable healthcare, partly through the employer mandate. However, the ACA may inadvertently push small firms toward riskier activities by financing their own healthcare plans.... In theory, small firms could be steered away from self funded plans by SHOP exchanges with attractive group policies. In practice, the deck is stacked against SHOPs. At the very least, the current tax credits available to very small employers for using SHOPs should be made permanent." (The Brookings Institution)
Consumers May Miss Out On Subsidies Due To Confusion About Job-Based Coverage
"Some of the confusion relates to the similar-sounding bureaucratic names for these different health law standards. Minimum value coverage means the plan pays for 60 percent of allowed medical charges, on average. Minimum essential coverage, which can include a range of things from grandfathered health plans to some of the prevention-only plans being offered by large employers, refers to what large employers must offer to avoid paying penalties for not offering coverage, as well as what individuals must carry to comply with the law's coverage requirement." (Kaiser Health News)
How the Healthcare Reform 'Bailouts' Work and How Some Insurers Are Farming Them
"The big difference between the Three Rs is that the first two Rs (the reinsurance and risk adjustment programs) either have a delineated flow of revenue support (the $63 tax on all health plans) or the payouts are to be limited to what the program takes in (all transfers are slated to balance out in the risk adjustment program - at least for now). The risk corridor program, however, has no set source of revenue. This means that if more insurers underprice their Obamacare plans in an effort to gain market share than plans who over-price, there will be a PPACA shortfall on this third R. Where would that money come from?" (Benefit Revolution)
[Guidance Overview] PPOs and Other Non-HMO Products Now Require Approval and Periodic Reviews of Network Adequacy in New York
"The New York Legislature recently enacted legislation that will require all health insurance plans that issue policies that provide for the use of a provider network to obtain network adequacy certification.... The standard for network adequacy is described as whether the network is sufficient to meet the health needs of the insureds and provide an appropriate choice of providers sufficient to render the services covered under the policy or contract." (Epstein Becker Green)
Millennials More Receptive Than Other Generations to Wellness Outreach
"More than half (52 percent) of Millennials said 'living or working in a healthy environment' is influential to their personal health, compared to 42 percent of Generation X and 35 percent of Baby Boomers. Millennials were also more open to having their direct manager play an active role in encouraging them to get and stay healthy (53 percent), compared to 47 percent of Generation X and 41 percent of Baby Boomers, and are most likely to participate in an employee assistance program (16 percent) compared to Generation X (10 percent) and Baby Boomers (8 percent)." (Society for Human Resource Management [SHRM])

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