leevena

I am a little confused about why the vendor would not be able to tell the employer who participated and received the gift certificate. You state HIPPA does not allow such notification, which comes as a suprise to me. Am I missing something here, what HIPPA sensitive information is being provided to the employer?

There are a couple of issues that come to mind when you ask "how hard is it to self-administer" an HRA? By the way, my suggestion is that you hire an administrator. You need plan documents, plan design, communication materials, decision how what expenses are eligible for HRA reimburesement, claim adjudication, claim payment (check issuance), someone at the employer needs to set up privacy safeguards, account balance activities, discrimination testing, and compliance testing. If your group is capable of doing all of this, let them self-administer. If not, pay the $ for someone who can.

I do not believe there is a law that covers the issue of data ownership...but I could be wrong. Rather, I would view it from the perspective of the buyer/seller relationship that existed when the group entered into an agreement with the tpa. Did the group not review what data was available? There are a variety of issues you should look at when selecting a tpa and one should be the types of reports available. Could it be that the employer entered into an agreement with the tpa and that agreement did not include this type of information? Not all tpa's are created equal.

GBurns...can't really remember. I am somewhat of a benefits junkie and tend to read as much as I can. I also taught the subject at university and other locations over the years. Since it was the late 40's or early 50's, I was not around so I do not know the specific reason(s) they were created, but I do remember that the plans became popular with ag business/small farmers for some reason.

A couple of things come to mind. The first is, you are correct in that the employer does own the data. If your client is self-funded, then the TPA does need to supply claim costs data to the client so that they can fund the account. I am guessing that this level of data is being made available. The second issue may be the ability of your client to obtain more detailed information beyond the usual date of service, service, cost, etc. If this is the case, then you may be running into a situation where the tpa is not able to develop such a level of detail in a report. So the question becomes, is the data/report available, or is the tpa unable to deliver such data/report. If the data/report is available, and part of the reporting package that your client purchased, then by all means it should be made available to you/client.

The differences between a Section 105 (MERP) and HRA are many, but for most people the answer is fairly short and simple. nherkowitz answers is somewhat correctly and that is where the nuances get drawn into. Section 105's originated in the early 50's and were used primarily in the ag business, mostly small farmers. As time progressed we started to use them as a partially self-funded health plan, where an employer purchased a large ded health plan and then superimposed a plan of benefits under that deductible. Those benefits were paid from an employer account. For example, the employer purchases a $5000 deductible, 100% thereafter, but tells the employees that there is a $500 deductble, 80/20 untile $5000. The employer funds the difference. There is also a market for highly compensated employees using the merp as a way to indemnify themselves for all out of pockets. Now comes along the new consumer driven plans. An HRA uses Section 105, along with othe codes. The IRS had to clarify a couple of issues, such as roll-over, cash-outs, and how to interact with FSA's. So if you were to do a detailed comparison of the two plans, there would be many things to compare. However, for the average layman and employer, what nherkowitz said is fairly close and I would use that. Where I disagree with nherkowitz, with all due respect, is the strategy between the two. The HRA is intended as a long-term strategy, whereas the 105 can be short-term. Unless very cash strapped, I would always recommend a carry-over provision for the client. This will provide the group with flexibility for the future. As the HRA funds accumulate, the employer has the ability to purchase less insured benefits and replace that corridor of risk with self-funded (HRA funds). Hope this helps.

Sounds like you are self-funding an employee benefit that allows the employee to pay only half of the physician charges. This is ok, but as I said earlier, make sure you have structured the plan correctly, including documents, communication, discrimination, etc.

Seems like you are asking if there is a federal requirement about chiropractic coverage in health plans? Is this correct? Insured plans are regulated at the state level, so I would check your specific state about their requirements. Also, a quick and easier way is to look at the coverages available through the health plans in your state, such as Blue's, Aetna, etc., becasue they are regulated by the states. The chance that they are marketing a plan that would violate these laws is very slim. Good luck.

This is a strange situation, and I agree with b2kates about whether this is truly voluntary. Also, how can someone overspend their fsa? You are asking about an FSA are you not? The enrollee tells the employer/administrator how much to deduct from their pay, say $2000, and then has more reimbursed, say $2500, and now wants to return the $500 to the employer? Bottom line is an employee could return any monies back to the employer. As for withholding it in the final paycheck, you might want to review your state's laws and see if that is legal. You further ask if they can pay off the extra amount with "pretax" dollars. Wasn't the initial dollars deducted pre-tax? If so, the employee received a tax break on these dollars that was not allowed in the first place. Seems like you might have a administrative problem IF I understand this.

I amsorry, but what does "academic differences" mean?

You need to provide more information, but my initial reaction is yes it can. It sounds like the hospital is providing the employees with an employee benefit, which happens to be the funding of services. This would be similar to a restaurant offering a discount on meals to their employees. Like any other company that offers an employee benefit, the question then becomes, "is the employer doing it correctly?" Did the company adopt the benefit, communicate it, apply it properly, etc. If they did, then it appears that it is ok. Good luck.

The regs allow for an enrollee to change their plan selection, such as add the dental to their coverage, but does not allow for the fsa amount to change.

By the way, I am a male. My comments are not about large groups, rather small. I am in San Diego and we have many carriers that will offer multiple plans to the 2-50 market. Aetna and BC will allow all of their prouduct line in at a group, which is upwards of 18 options. The larger market is a little more difficult to make a go at offering multiple plans. This is due primarily to the segmenting of the risk among different plans. It's not impossible, but you need to do some good homework and look for a group who has a long-term strategy. Since entering the field in 1982 I too have heard many new ways to solve our problem, and none seemed to work in the long-term. I do believe that cd plans do attack some of the problems, not all, but some. Of course in 10 years we may all be hearing about the next new thing.

Mary C---I don't disagree with everything that you said. The take-up rate of your lower paid employees should not be totally unexpected. Not knowing exactly what you are doing and why, I would say that the new option you are offering should help greatly. By offering the cd plan alongside traditional PPO, employees can choose what fits their needs, so someone who needs office visits, rx, etc can enroll in the PPO for that level of coverage. For those who don't they can try out the cd plan and see how it works. This all happened 20 years ago with the intro of HMO's, slow acceptance, slow take-up rates. There are a few keys to making your program work, including, good products, employer contribution levels, communication, education, and long-term thinking. If your employee benefit goals are short-term, cd plans are not always going to show the best results. As for your comment about them lacking the sophistication or knowledge to negotiate, so what? Your cd plan should have ppo discuounts built into them, and if not, you can purchase it. What they really need is a tool that will allow them to become more informed about health care.

Alexa....Something new occured to me this morning as I was reading the responses. Since you are part of a much larger organization that originally thought (you are part of a few insured and a few self-funded) did you not hire a COBRA administrator, or some other kind of assistance?

Sorry, no can do. I suspect you won't have too much of a problem though. It seems to me from the employee perspective the addition of a dental plan will decrease my out-of-pocket expenses. By decreasing my out-of-pocket expenses the employee may have over estimated their costs. For example, I sheltered $1500 of expenses due to expected dental expenses, but now some of that may be covered. I say you may not experience much of a problem is because 1) how many of those enrolled in the unreimbursed med FSA identified significant dental expenses, and, 2) since this is dental plan is on a virgin group, you may have some waiting periods or pre-ex's that will limit the amount of coverage provided by the dental plan. You may want to review these two factors and determine what kind of problem you may or may not have. Good luck.

Whether there is a network or not is irrelevant, it may be a hardship or cruel, but irrelevant. If an employee is in a network plan and moves out-of-area, tough luck. They can continue the current plan and either have emergency coverage only under the HMO or out-of-network coverage for the PPO. You may be able to allow them to change to another one of your plans, but you will need to check with those plans. Your best bet may be the self-funded, but I cannot say for sure.

I have to admit, this is a good series of questions and comments. Don...I don't disagree with most of what you say. However, the ability to accumulate large sums in a HSA is not that difficult. Over the past 10 years or so, my family has incurred maybe $10,000. As a family I could have funded my HSA by significantly more than that. I will grant you that there will be some who cannot. MJB...your comment does not make sense. You are suggesting that enrollees in HSA plans are required to pay the non-preferred rates to hospitals. Why? If I purchase a Blues HSA plan, I get the PPO rates at their providers. And, even if I purchase an insurance plan without a ppo network, I can still purchase a seperate ppo network to do the same. As for your comments about "hsa's never being a practical option", wake up, it's here. That was the same comment many people made about HMO's when they began to take off in the early 80's. JMOR99--don't worry about being blunt...I'am from Jersey were we take blunt to a whole new level. The level of uninsured is high, but not the 40 million or so. If you review those studies you will find that those numbers contain some "inaccurate" numbers. For example, if someone is uninsured for a short period of time, say two months because of change of job, they are listed as uninsured for the year. Additionally, it contains many who could have coverage, but choose not too enroll or spend money. But be that as it may, we still have too many uninusred. As for your comment about 2-75 life groups, here in San Diego we have Aetna, Blue Cross, PacifiCare, HealthNet, and Blue Shield that will all allow multiple plans, in fact, Aetna and Blue Cross allow 18 options. It may not be in your area, but it will soon.

Don. I agree wholeheartedly. There needs to be a few changes made, such as tax laws in some states, higher deductible amounts for enrollees with significant hsa funds, maybe debit cards with cash advances, consumer decision tools and more. The difference between what I am saying and your individual policy rising 60% is that enrollees will be able to select policy's with significantly less coverage, say 20 or 25 thousand dollar deductibles.

jmor99--I may not have been as clear as I could with my comments about HSA's being more affordable for more people, which you stated was "ludicrous" on my part. My comment was that the lower premiums offered by consumer driven plans will not insure all the uninsured, but rather, it will allow more people to buy insurance who in the past could not afford it. You say that the poor will take "a beating" from these plans. How do you see that occuring? We are not moving to an all HSA market, so they have the choice to not enroll in an HSA, and keep the plan they have now. A second point you raise about the unaffordability of these products is that an article you read said that only 1/3 of all HSA's have been funded. So what? You do not need to fund an HSA until either a claim is incurred or by April 15th of the following tax year. How many of these enrollees are waiting to fund when they need to fund? As I mentioned before, these products are not the cure all, but they are a step in the right direction. Let me lay out another scenario that I see occuring over the next 10-15 years. As people enroll in these products, some of them will be able to save significant amounts of dollars into a fund. As the HSA fund grows the enrollee can select a higher deductible/larger out-of-pocket exposure plan becasue they have funds on the side to cover that exposure. As the enrollee selects higher out-of-pocket plans, their premiums will decrease. The decrease in premiums will allow the enrollee to contribute more to the HSA fund. Imagine what a $15,000 deductible plan in your state would cost. I would imagine a family could get it for peanuts as compared to now.

Your point about low incomes does not make much sense to me. We all agree that consumer driven plans are usually considerably less than other plans. If a low income person cannot afford the lower cost consumer driven plan, how can the afford the current, higher cost plans? What a consumer driven plan does is lower premium to get more insured, not all insured.

I read this differently than JSB. It sounds like the question has to do with an employee who is already in a dep care fsa account and the only change is that the day care provider wants the entire summer payment (I am assuming 3 months) paid at registration. I agree with JSB's comments about payments. Also, if that is the situation, then I hope the day care provider was wearing a mask like all good thiefs should!

Good question. After 25 years in this business I start to wonder myself. My opinion is that consumer driven plans (HSA, HRA) are the first attempt in a long time to address some, not all, but some of the structural problems in our health care system. To begin with they bring the economics back into line and as a result start to chip away at the "womb-to-tomb" mentality that we have. The second issue is it should start to make enrollees more responsible for their health care, which should start to eliminate some wasteful spending. There are a whole set of other problems that these plans cannot address. The limited amount of slots available at medical schools keep the pool of physicians limited, thus raising their costs. To some extent, the same could also be said for the other providers in the system. The raw prices for medical services are driven by our society's want of only the very best, especially technology and drugs. Administrative costs are high. Years ago with the old indenmnity plans most admin costs were 5-7%. Now health plans are in the 15-20% range. Some of these additional costs are not their fault. Think of all the regulations that were put into place that they need to spend dollars on. What about the need for multi-lingual materials/staff. What about the need to go out and get NCQA approved? Many large employers demanded this, and then would leave a NCQA carrier for a non-NCQA carrier simply because of lower rates. Our system is broke and I don't know what the next steps will be, but for the time being the consumer driven plans seem like the best route. Just my thoughts.

I am not suggesting that the employer encourage enrollment in B instead of the plan. I am suggesting that the employee/medicare eligible person enroll in part B now. Sorry if I confused anyone.

You might want to start your research by looking at the various documents the current carrier supplied to you. I don't know what state or carrier you have, but start with the employee documents and also try the employer administrative kit (if one was provided). Also, you identified one particiular reason that someone can change their enrollment status off open enrollment time. There are a few others, which should be explained in the materials from your carrier. Good luck.