While hospitals in 34 geographic areas will still be required to participate in the Comprehensive Care for Joint Replacement Model, hundreds of acute care hospitals in other areas have received a reprieve. In addition to modifying CJR model compliance, CMS recently finalized plans to cancel the Episode Payment and Cardiac Rehabilitation Incentive Payment Models, both of which were scheduled to become effective on January 1, 2018.
While a number of hospitals will voluntarily participate in the CJR model and others have expressed interest to participate in the two cancelled models, the agency said there would not be enough time to restructure the models prior to the planned 2018 start date. Even though some have criticized the Trump administration for a lack of interest in value-based care, the administration has expressed a strong commitment to value-based payment, but says it prefers voluntary models.
In October, a bipartisan group of senators introduced a bill that would ease the ACA reporting mandates for employer-sponsored health plans. The bill would roll back the reporting requirements of Section 6056 and replace them with a voluntary reporting system. The bill would also allow payers to transmit employee notices electronically rather than having to send paper statements by mail.
While self-funded health plans must now comply with Sections 6055 and 6056, it is not yet clear how the bill would affect Section 6055 requirements. Senators Rob Portman of Ohio and Mark Warner of Virginia, sponsors of the bill, say their proposal would give the government a more effective way of applying premium tax credits to consumers who purchase insurance through an Exchange, something the administration has been trying to accomplish.
We often hear of professional athletes succeeding under pressure by staying “in the moment” and remaining focused on the things that are within their control. This challenge can be applied to the uncomfortable position all of us find ourselves in today – somewhere between complying with existing laws and anticipating the unknowns coming from Washington.
While the IRS has relaxed enforcement of the individual mandate and acknowledged problems in the ACA reporting system, it has confirmed that an applicable large employer is still subject to an employer shared responsibility payment if it fails to offer coverage to 95% of its full-time employees. We continue to help large employers offer minimum essential coverage to avoid penalties, when appropriate, and track offers of coverage to comply with reporting requirements on IRS forms 1094 and 1095.
Other matters remain up in the air as well, including the so-called Cadillac tax on high-cost health plans and any changes in maximum contributions that may be made to HSAs, which would require legislative action. While any significant ACA repeal, replace or repair efforts appear to be overshadowed by the Administration’s interest in tax reform, we continue to monitor developments in healthcare reform and keep our clients and partners informed. It’s our way of doing what we can and remaining “in the moment.”
The gradual transition to high deductible health plans is having a significant impact on out-of-pocket costs, according to a study released by the Kaiser Family Foundation/Health Research & Educational Trust. In 2016, for the first time, just over half of all workers (51%) with single coverage faced a deductible of at least $1,000. The study also showed that 29% of workers were in high-deductible plans compared to just 20% two years earlier.
With time running out on an opportunity for Congress to repeal and replace the Affordable Care Act and open enrollment season approaching, thousands of small and mid-sized businesses are likely bracing for another round of premium increases. A growing number of employers, however, will choose to avoid the uncertainty plaguing traditional group insurance markets by moving to a self-funded health plan – an option that provides an opportunity for savings and far more plan design flexibility.
Healthcare benefits continue to be perhaps the biggest obstacle facing small and mid-sized businesses. The Self Insurance Institute of America reports that between 2011 and 2016, the average annual deductible for employer-sponsored plans increased by 49% and the percentage of firms with fewer than 200 employees still providing health benefits fell from 68% in 2010 to 55% in 2016.
Self-funding on the other hand, has proven to be a far more responsible alternative for employers, enabling thousands to not only use their health benefit plan to attract and retain high quality employees, but to do so at an affordable cost. While self-funding has long been a staple for the nation’s largest employers, nearly a third of companies with 200 or more employees now offer at least one self-funded option.
Everyone Benefits from Flexibility
There are many reasons for the growth of self-funding, with flexibility and access to valuable claims data high on the list. Since self-funded plans are governed by ERISA, they avoid many of the costly mandates governing fully insured plans. To manage risk, stop loss coverage is obtained to cover claims that exceed anticipated levels. If claims are below anticipated levels, the plan retains the savings that would have been paid to an insurance carrier in the form of non-refundable premiums. Benefits can be customized to meet the unique needs of the group. When an independent TPA is engaged to administer the plan, claims data can be analyzed to identify chronic conditions and other key cost drivers. Services such as telemedicine and mobile transparency tools can be added to make physician access more convenient and more affordable. From plan design to data analysis, everyone benefits from the flexibility that a self-funded plan can provide. It’s the biggest reason why more small and mid-sized companies continue to move to self-funding with help from an independent TPA.
According to Deloitte Consulting LLP, small and medium sized employers with 100 or more workers are contributing considerably more towards the cost of employee and dependent healthcare benefits than legally required – about 73% of the total cost, on average. Regional differences also exist, with companies in the Northeast contributing more toward the cost of family coverage and companies on the West coast contributing more to individual coverage.
Even as healthcare costs continue to increase, consultants agree that employers of all sizes will continue to contribute significantly to healthcare benefits as the job market continues to tighten and retaining top talent remains a top priority.
40 Square Cooperative Solutions, a health care cooperative formed to help Minnesota agricultural producers and their employees obtain affordable health care coverage, officially began open enrollment on November 1st.
40 Square contracted EBSO to design and administer new self-funded health plans. With the cost of health insurance continuing to skyrocket throughout the U.S., forming a health care cooperative has been on the minds of Minnesota farm families for many years.
During the 2017 legislative session, the Legislature and Governor Mark Dayton approved a law that enabled farmers, in Minnesota, to form health care cooperatives to provide a LONG TERM SUSTAINABLE HEALTH PLAN option for farmers. The rule paved the way for 40 Square Cooperative Solutions to begin offering a self-funded health plan to Minnesota farmers.
Farmers who are considered an ‘employer’ with at least one common law employee and work in production agriculture in MN are eligible. Once part of the co-op, employees can register for 40 Square Consortium self-funded health plan. Those interested will work with a broker to make sure the best individual or family plan is chosen.
EBSO, who is based in St. Paul, MN, is proud to have been contracted as the third party administration (TPA) firm to design and administer the new self-funded health plans.
“Flexibility and cost control have long been advantages of self-funded group health plans and the 40 Square Cooperative plan is no exception,” stated Terri Moxley, Senior Sales Specialist with EBSO. “To meet the specific needs of Cooperative members and their families, six different plan designs will be available when open enrollment begins on November 1, 2017,” Moxley added.
For more on the member-owned health care cooperative, visit www.40square.coop online, call 800.643.5822 or speak with your insurance agent.
Mention healthcare startup and you probably think of Silicon Valley. Surprisingly, there’s plenty of healthcare technology happening in the Midwest, with Minnesota leading the way. According to Twin Cities magazine, 98 health technology startups raised more than $420 million in capital in 2016 alone, bringing the total to $2.75 billion since 2009. From mobile app developers to medical device manufacturers, more than 430,000 Minnesotans are employed by healthcare-related companies.
Health savings accounts are hot, with nearly two-thirds of respondents to a Plan Sponsor Council of America survey saying they believe that even those without a high deductible health plan should qualify. A benefit often cited by employers and employees alike is that HSAs can be a valuable part of one’s retirement strategy, since healthcare expenses are viewed as one of the largest people face in retirement.
All the talk about repeal and replace seems to have lulled many plan sponsors into a false sense of security, thinking that ACA regulations weren’t going to be enforced. Unfortunately, the IRS is preparing to begin penalizing non-compliant plans, which is why we continue to encourage our clients to keep their eye on the ball even though it is easier to follow the media frenzy coming from Capitol Hill.