Transcript Slide 1

Health Care Reform
Implementation Update
Steve Peebles
Staff Vice President
Account Management
Implementation
Responding to guidance
Guidance
issued
How do we put this into place with
the least disruption for customers
and members?
Implement and communicate
Key terms
How might the rules affect
customers and members?
Submit comments
▪ Guidance – Proposed rules, final rules, clarifications,
etc., issued by HHS and other federal agencies
▪ HHS – Department of Health and Human Services
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Summary of Benefits & Coverage
Final Rule (issued on 2/9/12):
▪ Compliance Date = Required for open enrollments
beginning on or after September 23, 2012
▪ Format = Issuers must use template developed by NAIC
▪ Delivery = Electronic is acceptable and can be used for
“pre-enrollees”
▪ Premium field = Requirement has been omitted
▪ Coverage examples = Reduced from 3 to 2
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Summary of Benefits & Coverage – Format
75 data elements
• Automatically generated
• Systematically running process
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Merrill Solution – Creates Electronic Workflow
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Notice of material modification
At least 60 days’ notice of material
modifications to the plan:
▪ Does not apply to renewals of coverage
▪ Can be satisfied with an updated SBC if
the change is reflected on the SBC
Employer to-do list
▪ If self-insured, provide a notice or
updated SBC at least 60 days before
making off-cycle changes.
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Women’s Preventive Guidelines
New guidelines take effect for policies (non-grandfathered)
with plan years beginning on or after August 1, 2012
100% covered in-network per ACA Preventive requirement
There are 4 types of preventive care services (out of the total
of 8) required by HHS, including new coverage:
▪ Screening for Gestational Diabetes (new coverage – 3 codes)
▪ HPV Testing (new coverage – 3 codes)
▪ Contraceptives and Counseling females only
(new medical and Rx coverage)
▪ Breastfeeding Support, Supplies, Counseling
(new equipment coverage)
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Spending account changes
Health care
flexible spending
account (FSA)
Health
reimbursement
arrangement (HRA)
Health savings
account (HSA)
Prescription required for OTC
reimbursement (2011)
Higher penalty for nonqualified
distributions (2011)
Cap on contributions (2013)
Employer to-do list
▪ Make sure your employee benefit materials
reflect the new spending account rules.
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W-2 reporting
Required dates
▪ Employers who issue 250 or more W-2s:
• 2012 tax year (forms issued January 2013)
Employer to-do list
▪ Make sure your payroll department or vendor is
prepared for W-2 reporting.
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Comparative effectiveness research plan fees
To be paid by plan sponsor (for self-insured) or plan issuer
(for fully insured)
Plan/policy year ending during …
Fee
Fiscal year 2013
$1 multiplied by the average number of covered lives
Fiscal year 2014
$2 multiplied by the average number of covered lives
Fiscal year 2015 – 2019
$2 (adjusted for inflation) multiplied by the average
number of covered lives
Employer to-do list ▪ If self-insured, pay these fees starting with
your first renewal after October 1, 2012.
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Employer to-do list
Now
All employers: Make sure your employee benefit
materials reflect the new spending account rules,
if you offer such plans (FSA, HRA, HSA)
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2012 or 2013
All employers: Make sure your
payroll department or vendor is
prepared for W-2 reporting.
Self-insured groups: Pay
comparative effective research
(PCORI) fees starting with your first
renewal after October 1, 2012.
All employers with 100% preventive benefits:
Coverage for additional women’s health services
should be added at your first renewal on or after
August 1, 2012.
Self-insured groups: Provide a material
modification notice or updated SBC at least 60
days before making off-cycle changes.
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