Transcript Document

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HEALTH CARE REFORM:
KEY CONCEPTS FOR EMPLOYERS
NOVEMBER, 2010
7/7/2015
Greg Dattilo, CEBS
Freemarkethealthcare.com Team
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
Greg Dattilo, CEBS

Dave Racer, MLitt
35 years experience as
employee benefit consultant
Master of Letters from
Oxford Grad School
President of
Dattilo Consulting, Inc.
Thesis: Comprehensive
Health Care Reform
Wharton School of
Business
President of
DGRCommunications, Inc.
Incoming President
MN AHU - Chair of
Legislative Committee
Publisher, Speaker
Author, Teacher
Lectured in 28 states – Dozens of articles – National Surveys
7/7/2015
Four books since 2004
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


Your Health Matters: What You Need
to Know About U.S. Health Care
Development of government and private
insurance plans in the United States
Report on nationalized health care systems of:

Canada

United Kingdom

Germany

France

Japan
336 pages – Hardcover
Released April, 2006
7/7/2015
Four books since 2004
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

FACTS: Not Fiction – What really
ails the U.S. health care system
Common myths, misconceptions, and
deceptions



Infant mortality, life expectancy,
uninsured rate, admin cost
Socialized health care – Discriminating
against the most vulnerable
Americanized U.S. health care
64 pages – paperback
Released January, 2008
Nearly 100,000 Distributed
7/7/2015
Four books since 2004
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
Why Health Care Costs So Much: Six
Book Series
 The
Solution: Consumers - 2009
 Governments’ Real Role - 2010
 Employers
 Providers
 Payers
 Faith community
7/7/2015
Today’s discussion
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



Part 1: Why health care costs so much
Part 2: Will the new health care law reduce costs?
Part 3: Alternate solutions to the new law
Part 4: 2011- Strategies to control insurance cost
7/7/2015
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How people with health insurance
bought health care pre-1966
Paid the first
dollars for their
own health care
42%
Out of
Pocket
Patient Driven
Health Care
Doctors &
hospitals
Payers
Decided what to
buy and from
whom – Options
for low-income
Provided care: In
home and clinic
Paid catastrophic
claims: They were
insurance companies
7/7/2015
U.S. Health Care Prior to 1966
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

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
Individuals paid 42 cents out of each $1.00
themselves. Someone else paid 58 cents. (1965)
Hospital daily room rate of $17-$19
Health care inflation about the same as other
consumer prices
Government delivered care based on need, at
government facilities
Everyone had access to care
7/7/2015
U.S. Health Care 1965-1973
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
Expansion of government entitlements
 Medicare




and Medicaid
Medicare: Qualified by age, not financial or even
physical need
Medicare changed delivery from government
facilities to private facilities
Medicare tax started at .7% of first $5,480.
Maximum annual tax of $39.20
Medicaid benefits were not catastrophic, but broad
and rich (even richer than private plans)
7/7/2015
U.S. Health Care 1973-2002
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
Congress passed HMO Act – 1973

Prepaid health care




One price, all services included
Added maternity, preventive, and elective surgery coverage
Copied government health benefits to private health insurance
Congressional Justification: Short term cost would
increase, but long term cost would be less

“Catch the illness before it became too costly.”
7/7/2015
Prior to HMOs, Ala Carte Health Care
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Like ordering off a menu



You are more likely to
clean your plate.
Or, you ask for a
doggy bag. You do not
throw away the extra
food.
You eliminate waste.
7/7/2015
HMO is like a buffet dinner
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
How do you measure a
buffet’s value?
 By
how many plates of
food you consume.
 Three
plates of food is
“three times the value”
of one plate.
7/7/2015
Waste is accepted at a buffet
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
You may throw away
food, but it’s okay. You
paid for it.
As others throw away
food, the price for
everyone will
eventually increase.
7/7/2015
U.S. Health Care 1973-2002
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
Behavior changed from:
 Prudence
to waste
 Healthy behavior to unhealthy behavior
7/7/2015
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7/7/2015
1965 – 2009 Price Trends
16

Since 1965:


Military spending has increased 1,177%
Federal and state public education spending has
increased 2,950%
 Spending
on health care has
increased 6,000%
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cents
$16.80
gal
aagal
1965
2009
7/7/2015
Hospital Price Spikes
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
1965: University of Virginia Hospital Daily Rate
 $17

to $19 “spiked” to $22 a day
2007: According to the American Hospital
Association:
 Average
daily room charge is $1,696
 7,700 percent increase over 1965

What has contributed to this spending increase?
 Demand
- Entitlement
7/7/2015
U.S. Health Care 2003-2009
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

Congress endorses consumer managed insurance
plans (consumer-directed health plans)
Congress allows individuals to set up Health Savings
Accounts, with very few regulations
An attempt to reverse the entitlement mentality and
wasteful behavior caused by prepaid health care
and government-subsidized health plans
7/7/2015
US Population- 3:30 pm 9/9/10: 310,207,152
Covered, by category*

Medicare, aged 65 and
over
Medicare, under age 65
Medicaid, CHIP, Military,
VHA, and other
government programs
2009 CHIP Added

Total Covered - Gov


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
34 million

7 million

58 million

4 million

103 million
* Congressional Budget Office-12/2008
7/7/2015
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Entitlement 2010
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Today, three of every 10 are in the wagon
7/7/2015
Part 2:
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Will the new health care
law reduce cost?

7/7/2015
U.S. Health Care – 2010 to 2013
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



Congress passed and Pres. Obama signed the
Affordable Care Act of 2010 on March 23,
amended on March 30, 2010.
2,800 pages of new laws
Tens of thousands of pages of new regulations
Government transition period
7/7/2015
Meet the new CEOs of health care
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Her title appears
more than 3,000
times in the ACA.
Kathleen Sebelius
159 New commissions, boards,
study groups, and grant makers
7/7/2015
Policymakers drive policy
Secretary and presidential appointments are critical
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


Dr. Donald Berwick
Pres. Obama just
appointed as CMS chief
“I cannot believe that the
individual health care
consumer can enforce
through choice the proper
configurations of a system
as massive and complex
as health care. That is for
leaders to do.”
7/7/2015
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How Americans will buy health care
after passage of ACA of 2010
The Federal Government will
set foundational health
care policy, and design
basic health plans.
Payers
Providers
Patients
7/7/2015
Federal subsidies for you and/or your neighbors
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The 2009 Poverty Guidelines
Qualified for Subsidy
At $400% of FPG
Persons in Family
Poverty Guideline
400 Percent of FPG
1
$10,830
$43,320
2
$14,570
$58,280
3
$18,310
$73,240
4
$22,050
$88,200
“Modified” Adjusted Gross Income
7/7/2015
Federal subsidies for you and/or your neighbors
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The 2009 Poverty Guidelines
Qualified for Subsidy
At $400% of FPG
Persons in Family
Poverty Guideline
400 Percent of FPG
1
$10,830
$43,320
2
$14,570
$58,280
3
$18,310
$73,240
4
$22,050
$88,200
5
$25,790
$103,160
6
$29,530
$118,120
7
33,270
$133,080
“Modified” Adjusted Gross Income
7/7/2015
Making insurance affordable
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“For most families, the cost of health insurance will go down.”
How? Shifting Cost to someone else.
Consider: Family of 4, with family income of $80,000
Policyholder’s
Age
Low Cost Area
Annual Subsidy
Med. Cost Area
Annual Subsidy
High Cost Area
Annual Subsidy
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$0
$1,036
$2,763
45
$1,264
$3,480
$5,695
55
$4,689
$7,761
$10,834
60
$7,360
$11,100
$14,840
Kaiser Family Foundation: Health Reform Subsidy Calculator
7/7/2015
Making insurance affordable
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“For most families, the cost of health insurance will go down.”
Consider: Family of 4, with family income of $40,000
Policyholder’s
Age
Low Cost Area
Annual Subsidy
Med. Cost Area
Annual Subsidy
High Cost Area
Annual Subsidy
35
$4,731
$6,458
$8,186
45
$6,686
$8,902
$11,118
55
$10,111
$13,183
$16,256
60
$12,782
$16,522
$20,262
Kaiser Family Foundation: Health Reform Subsidy Calculator
7/7/2015
Based on family of 4
Subsidies for upper middle income employees

Poverty level-Family of 4

$22,050

Two times FPL
 82.3 million (31%)

$44,100
Three times FPL With 65 & Over
 127 million (48%)68% of




$66,150
Modified Adjusted
Gross Income
 $88,200
Four times FPL
the
 163.5 million (62%)
population
Five time FPL
 192 million (73%)

$110,250
7/7/2015
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New Federal Law: Entitlement - 2014
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Seven of every ten will be in the wagon
7/7/2015
Herding Us Into Health Insurance Delivery Models
The Exchange – 1/1/2014
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
Could be state, or could be federal, but “must be”
Internal Revenue Service
Assess penalties for uninsured
Verification of financial data
Collection of penalties
CMS
Secretary of HHS
State Government
Analyze health data
Create practice guidelines
Health Data from
insurance
companies
One
Exchange
for both
Individual
Insurance
Individuals
Comparative Effectiveness
Small Groups
Small
Group
Insurance
All Subsidized Plans
Gov’t Plans
7/7/2015
Exchange Health Plan Selection Question
for Individuals
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
Basic health information
Identify doctor and hospital of choice
Concern: Cost, provider, overall quality (quality in a
particular area)
Choose plan level (bronze, silver, gold, platinum)
Exchange calculator example: Part D Medicare
7/7/2015
Exchange data management
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
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Secretary (HHS) will develop rating system of
qualified health plans
Dashboard: Performance of insurance company
customer service and claim accuracy
Chosen plans with data from preferred physicians
and hospitals
Identify high cost chronically ill members whom
insurance companies will be required to contract
after enrollment
7/7/2015
Exchange Employer (ER) Enrollment
35



Employer registers – secure login – exchange
verifies small ER eligibility – unemployment tax
filings
ER chooses health plan tier – amount EE contributes
for individual or family per benchmark plan
ER signs electronic agreement regarding equal
treatment of employees
7/7/2015
Exchange Employer (ER) Enrollment
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

ER discloses name, date of birth, SSN of each
eligible EE
Exchange must verify ER requirement of minimum
payment to EE insurance, both in and out of the
exchange
7/7/2015
Exchange Employee (EE) Enrollment
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

EE goes to Internet or calls call center or insurance
agent
EE gives information to match with ER.
 May

undergo screening for Medicaid eligibility
EE selects plan, pays required premium. For
benchmark plan, plus any buy up plan difference
7/7/2015
Exchange Premium Payment Options
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


All premium paid to the exchange – exchange pays
insurance company, accurately tracks those
breaking or not breaking the law
First payment to exchange then to insurance
company (multiple ER payments to insurance
company)
All payments to insurance company (does not allow
accurate tracking and multiple ER payments to
insurance companies)
7/7/2015
Individual tax credits for premium
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

Tax credit to pay for second lowest silver plan
Tax credit amount equals the excess premium based
on percent of your income
Income Level
Percent Allowed to Pay
Below 133% of FPL
2%
134%-150%
3%-4%
151%-200%
4%-6.3%
201%-250%
6.3%-8.05%
251%-300%
8.05%-9.5%
301%-400%
9.5%
7/7/2015
Cost Sharing Subsidies
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

Out of pocket cost is limited to individual between
100%-250%
Subsidy pays up to the following actuarial values:
Percent of FPL
Actuarial Value
100%-150% FPL
94% value
150%-200% FPL
87% value
200%-250% FPL
73% value
7/7/2015
Small Employer Health Plan - Tax Credit
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



No more than 25 full time equivalent employees
Less than $50,000 average annual wages
Employer pays 50 percent or more of employee
coverage
Excludes owners and family members
7/7/2015
Tax Credit
For-Profit Organization: Best Scenario
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



Assumption: 13 employees earning minimum wage
of $7.25 per hour
Single coverage - $4,704 average annual premium
in MN
35 percent tax credit of $21,403 received only if
credit equals tax from profitable year
Cost to profit: $39,749, $1.76 per hour: 24.3
percent of additional compensation
7/7/2015
Tax Credit
Non-Profit Organization: Best Scenario
43




Assumption: 13 employees earning minimum wage
of $7.25 per hour
Single coverage - $4,704 average annual premium
in MN
25 percent tax credit - $15,288 received only if
payroll tax equals or exceeds
Cost to non-profit: $45,864, $2.03 per hour, 28
percent of additional compensation
7/7/2015
New Laws in 2010
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

Unlimited health care benefits for all fully-insured and selfinsured groups and individual plans that begin or renew on or
after October 1, 2010. (No more $1 million/$2 million
maximums.)
Annual benefit limits will be allowed only through plan years
beginning prior to January 1, 2014, and only on DHHSdefined, non-essential benefits.
 Example:
2010 Rx Maximum $
7,500
2011 Rx Maximum $ 750,000
2012 Rx Maximum $1,250,000
2013 Rx Maximum $2,000,000
7/7/2015
2014 Rx Maximum Unlimited
New Laws in 2010
45

All health insurance plans, including self-insured
plans, renewing on or after October 1, 2010, will
have to cover dependents up to age 26.
Extended to grandfathered plans.
 Dependents could be married and would be eligible for the
group health insurance income tax exclusion.
 Through 2014, grandfathered group plans would only have
to cover dependents that do not have another source of
employer-sponsored coverage.

7/7/2015
New Laws in 2010
46

All group and individual health plans, including
self-insured plans, will have to cover preexisting
conditions for children 19 and under for plan years
beginning on or after October 1, 2010.

Grandfathered status applies for group health plans
7/7/2015
New Laws in 2011
47



The tax penalty on distributions from a health
savings account that are not used for qualified
medical expenses increases from 10% to 20%.
Cost of over the counter drugs will no longer be an
eligible expense under HSAs, FSAs, HRAs and
Archer MSAs (unless prescribed by a doctor).
Creates the CLASS Act, a new public long-term
care program and requires all employers to
enroll employees: The employee may elect to opt
out.
7/7/2015
New Laws in 2012
48
•
All employers must include on each employee’s W2 the
aggregate cost of employer-sponsored health benefits.
 Applies to benefits provided during taxable years after
December 31, 2010.

If employee receives health insurance coverage
under multiple plans, the employer must disclose
the aggregate value of all such health coverage, but
exclude all contributions to HSAs and Archer
MSAs and salary reduction contributions to FSAs.
7/7/2015
New Laws in 2012
49

All employers, including those with self-funded plans, must
provide a summary of benefits and a coverage explanation to
all enrollees, in addition to the current Summary Plan
Description (SPD), that meets the following criteria (notices
must be provided 60 days in advance):





when they apply for coverage,
when they enroll or reenroll in coverage,
when the policy is delivered,
and identify any material modification made to their coverage.
The summary and explanation can be provided electronically
or in written form, and there is a $1,000 per enrollee fine for
willful failure to provide the information.
7/7/2015
New Laws in 2013
50

The threshold for the personal itemized deduction for
unreimbursed medical expenses increases from 7.5%
of AGI to 10% of AGI.


The increase would be waived for individuals age 65 and
older for tax years 2013 through 2016.
$2,500 Cap on Medical FSA contributions, annually
indexed for inflation begins.
7/7/2015
New Laws in 2014
51

Guarantee issue coverage, with no pre-existing
condition exclusion, for all health insurance policies
(wait until you’re sick, and then buy insurance).
7/7/2015
New Laws in 2014
52

Strict modified community rating standards All
individual health insurance policies and all fully
insured group policies 100 lives and under (and
larger groups purchasing coverage through the
exchanges) must abide by with premium variations
only allowed for age (3:1), tobacco use (1.5:1),
family composition and geographic regions to be
defined by the states and experience rating would be
prohibited.
7/7/2015
New Laws in 2014
53

The current workplace wellness incentives has a
maximum of 20 percent of employee premium. This
maximum increases to 30 percent, and possibly to
50 percent (if the federal government agency
approves).

Redefines small group coverage as 1-100
employees.

States may apply for a waiver to reduce this number to 50
for plan years prior to January 1, 2016.
7/7/2015
New Laws in 2014
54


An employer with more than 50 employees that offers coverage, but has at
least one FTE receiving the premium assistance tax credit, will pay the
lesser of $3,000 for each of those employees receiving a tax credit, or $750
for each of their full-time employees total. (Breakeven is 13 employees
receiving the tax credit.)
An individual with family income up to 400% of FPL is eligible for a
premium assistance tax credit if the actuarial value of the employer’s
coverage is less than 60%, or the employer requires the employee to
contribute more than 9.5% of the employee’s family income toward the cost
of coverage.
7/7/2015
New Laws in 2014
55

Requires employers to give a voucher to use in the individual
market or exchange instead of participating in the employerprovided plan.





Employees must be ineligible for subsidies
The value of vouchers the employer contribution adjusted for age
Employee can also keep amounts of the voucher in excess of the cost of
coverage elected in an exchange without being taxed on the excess
amount.
Establishes standards for qualified coverage, including
mandated benefits, cost-sharing requirements, out-of-pocket
limits and a minimum actuarial value of 60%.
Allows catastrophic-only policies for those 30 and younger.
7/7/2015
New Laws in 2014
56

Requires all American citizens and legal residents to
purchase qualified health insurance coverage.
Exceptions are provided for :

religious objectors,

individuals not lawfully present

incarcerated individuals,

those who cannot afford coverage,

taxpayers with income under 100 percent of poverty,

members of Indian tribes,

those who have received a hardship waiver

those who were not covered for a period of less than three months during the
year

People with no income tax liability
7/7/2015
New Laws in 2014
57



Penalty for non compliance to either a flat dollar amount per
person or a percentage of the individual’s income, whichever is
greater.
In 2014 the percentage of income determining the amount of
the fine will be 1%, then 2% in 2015, with the maximum fine
of 2.5% of taxable (gross) household income capped at the
average bronze-level insurance premium (60% actuarial) rate
for the person’s family beginning in 2016.
The alternative is a fixed dollar amount that phases in
beginning with $95 per person in 2014 to $695 in 2016.
7/7/2015
New Laws in 2014
58


All employers must provide coverage documentation to
covered individuals and the IRS.
Requires employers of 200 or more employees to autoenroll all new employees into any available employersponsored health insurance plan.




Waiting periods subject to limits may still apply. (Employer is fined
for waiting periods greater than 60 days)
Employees may opt out if they have another source of coverage.
Implementation date is unclear, may change to earlier via regulation
Requires all employers provide notice to their
employees informing them of the existence of an
Exchange.
7/7/2015
New Laws Beyond 2014
59



CHIP Reauthorized in 2015
Groups 100+ may be allowed into the Exchanges in 2017 if state
elects
40% excise tax on insurers of employer-sponsored health plans with
aggregate values that exceed $10,200 for singles and from $27,500
for families takes effect in 2018.




Delayed from 2013 by reconciliation bill.
Transition relief would be provided for 17 identified high-cost states.
Values of health plans include reimbursements from FSAs, HRAs and employer
contributions to HSAs. Stand-alone vision and dental are excluded from the
calculation.
Reconciliation bill reduced the formula for indexing the thresholds even further (to
just inflation, not inflation plus 1%) so that more plans will fall under the tax faster,
but also allows plans to take into account age, gender and certain other factors that
impact premium costs.
7/7/2015
Today: Pieces [sort of] fit together
60
?
ACA
Copyright 2010: DGRCommunications, Inc.
7/7/2015
Neat, orderly, rigid, managed top down
61
?
ACA
Copyright 2010: DGRCommunications, Inc.
7/7/2015
A look at your future health care system
62
?
ACA
Copyright 2010: DGRCommunications, Inc.
7/7/2015
Where this leads
63
ACA
Copyright 2010: DGRCommunications, Inc.
7/7/2015
Part 3:
64
Alternative solutions to
the new law

7/7/2015
Real Solutions
65

Sensible Redesign of Health Care Delivery
 Emptying,
not loading, the Wagon (GovCare)
 Common sense, private health care reform
7/7/2015
Emptying, not loading, the Wagon
66


Who should be in the wagon?
Where should those in the wagon
receive their health care?
7/7/2015
Who should be in the wagon?
67
Category
Situation
Disabled
Unable to work: No financial assets
Unable to work: With financial assets
Able to work: With financial assets
7/7/2015
Who should be in the wagon?
68
Category
Chronically Ill
Situation
Unable to work: No financial assets
Unable to work: With financial assets
Able to work: With financial assets
7/7/2015
Who should be in the wagon?
69
Category
Healthy, Able
Bodied
Situation
In-between jobs: No financial assets
In-between jobs: With financial assets
Employed: No financial assets
Employed: With financial assets
Choose unemployment: No financial assets
Choose unemployment: With financial
assets
7/7/2015
70
Where should those in the wagon
receive their health care?



A place with minimal admin cost, but maximum
dollars spent on medical care
Medicaid services in 2009 spent $180 billion on
admin – 26% lost to admin cost: Replace with
GovCare
As many as 50% of doctors refuse new Medicaid
patients today (low reimbursements) creating long
wait times, and potential shortage of critical care:
Replace with GovCare
7/7/2015
71
Where should those in the wagon
receive their health care?




The truly poor cannot afford out-of-pocket costs:
Replace with GovCare
Complicated government forms and procedures
discourage the neediest from enrolling in Medicaid:
Replace with GovCare
Medicaid billing fraud wastes at least $30 billion a
year: Replace with GovCare
Out of control Medicaid spending threatens state
budgets: Replace with GovCare
7/7/2015
72
Where should those in the wagon
receive their health care?




As much as 30% of medical expense results from
defensive medicine: Replace with GovCare
Lack of individual medical history at time of
medical need results in unnecessary spending:
Replace with GovCare
Difficulty in managing an individual’s health care
needs: Replace with GovCare
High cost of emergency room care for routine, minor
illness: Replace with GovCare
7/7/2015
Who qualifies for GovCare?
73


Those who do not have private insurance
Those who are unable to pay for private
health care
7/7/2015
What is GovCare?
74



GovCare is the health care delivery system used
prior to 1966 for those who could not afford
private health care
In GovCare days, health care spending increased
at the same rate as CPI
In GovCare days, health care was affordable for
most, and available for everyone
7/7/2015
What is GovCare?
75

GovCare is what we have now, but for those
without private health insurance, delivered at
government facilities
 Community
health centers (more than 8,000 today)
 County hospitals
 Other government hospitals


GovCare is provided by government-employed
medical professionals
It completely eliminates the issue of individuals
who are uninsured
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
Stop paying medical providers who have to correct
their own mistakes (gross errors) - Some examples:
 Hospital-borne
infections
 Repeating procedures to get it right
 Missed diagnosis
 “Non-Events”
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



The GAP Plan: Guaranteed, Affordable, Portable
coverage
Guaranteed issue with no pre-existing condition
exclusions
Affordable, low-cost catastrophic policy: An
alternative to high cost COBRA
Portable insurance to take with you in-between
employment
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

The APT Plan: Affordable, Price
Transparent
Affordable, as a result of a
scheduled reimbursement
 Based
Doctor charges:
$200.00
Medicare allows
$100.00
on Medicare reimbursements
 You choose the reimbursement level,
set at a percent above the Medicare
schedule (Ex. 130% - 150% -170%)
 You can go to any doctor you choose
in the United States
You have a 150%
APT plan
Plan pays $150
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You pay $50
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



PAS Plan: Predictable, Affordable, Stable
Pass the claim on to the Pool
2% of the population drives 50% of health care
spending in any given year
Pools the high cost claims, and pays the cost through
a Health Care User Tax (2%)
 Recycling
money: Tax pays the providers
 Like a gasoline tax
 Money pays for care, not for insurance premiums
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Part 4:
80
2011 strategies to control
insurance cost

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81
STRATEGIES TO CONTROL
INSURANCE COST

FINDING WASTED DOLLARS IN MEDICAL
INSURANCE PREMIUM
 Spousal
surcharge program
 Defined Contribution
 Medicare-eligible employees – retirement
 Health Reimbursement Arrangements (HRA)
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STRATEGIES TO CONTROL
INSURANCE COST

CHANGE EMPLOYEE HEALTH CARE BUYING
BEHAVIOR
 Pay
less to insurance companies, and more to your
employees
 Engage your employees in health purchase decisions
with their money
 Teach employees to ask, “How much does this cost?”
when they receive medical care
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STRATEGIES TO CONTROL
INSURANCE COST

USING TAX INCENTIVES TO MOTIVATE
EMPLOYEES
 Employer
paid disability benefit is 100% taxable to
employees at time of disability
 Make the disability payment 100% tax free at the time
of disability
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STRATEGIES TO CONTROL
INSURANCE COST

GIVE CHOICES TO EMPLOYEES TO CAP YOUR
COST
 Dual-option
medical plans
 Use different plan designs or different networks
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STRATEGIES TO CONTROL
INSURANCE COST

STRATEGIES TO COST-EFFECTIVELY RETAIN KEY
EMPLOYEES
 Structure
employee classes
 Executive medical reimbursements insurance
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STRATEGIES TO CONTROL
INSURANCE COST

USE EMPLOYER SIZE TO LEVERAGE LESS COSTLY
EMPLOYEE OPTIONS
 Using
your employees as a purchasing group to reduce
individual cost
 No direct employer cost, except payroll expense
 Voluntary benefits for employees and dependents
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HEALTH CARE REFORM:
KEY CONCEPTS FOR EMPLOYERS
NOVEMBER, 2010
7/7/2015
Greg Dattilo, CEBS