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Families First Coronavirus Response Act Impact on Benefits

Fri, 20 Mar 2020 16:36:27 GMT

Families First Coronavirus Response Act (FFCRA)

In light of COVID-19, many schools and businesses are being forced to make changes including closings, layoffs, and remote workforces. The Families First Coronavirus Response Act (FFCRA) was signed into law on March 18, 2020, by President Trump. The FFCRA is the first attempt by the federal government to provide relief to workers and their families facing the economic fall-out of COVID-19. It includes provisions to help employees and their employers, by providing emergency paid sick leave and temporarily expanding the Family and Medical Leave Act (FMLA) to allow paid family leave for working families affected by school closures. All of this can leave employers and their employees uncertain about the future and have them asking about benefit elections changes and how to handle benefits during employee leave or business shutdowns.

Emergency Paid Sick Leave

The FFCRA creates a new Emergency Paid Sick Leave Act (EPSLA) which, effective April 2nd through the end of 2020, requires employers with less than 500 employers to provide paid sick leave to individuals who cannot work (including remote work) due to isolation/quarantine orders, having symptoms of COVID-19, caring for another person in one of those categories, or caring for a minor child due to school or daycare closures.

FMLA Expansion

Additionally, the FFCRA provides longer paid leave and extends FMLA protection through December 31, 2020 if an employee needs to care for a child under age 18 if their school or daycare is closed for reasons related to the current public health emergency.

Maintaining Employee Benefits for Employees

It is important to understand an employer's obligation to maintain benefits during leave. In general, if an employee is on a paid leave of absence, they will retain benefits eligibility as long as they are receiving any regular pay from their employer. On the other hand, if an employee is on an unpaid leave, their benefits eligibility will depend on the type of leave and the employer's leave policy.

Please note that at this time, the rules about changing benefit elections on a voluntary basis have not changed. This means that unless they experience a permitted election change event, including a leave of absence, participants typically will not be able to adjust benefit elections under a cafeteria plan, such as their medical or prescription drug, dental or vision coverage, or Health Care FSA elections. Keep in mind, however, that Dependent Care FSA elections are more flexible, and participants can change these elections if they experience a change in daycare providers or the cost of dependent care.

For the complete article, please read this week's Compliance Buzz .

Million-dollar medical claims increase by 87 percent

Wed, 18 Jul 2018 17:57:52 GMT

Injectable drugs and in-patient care drive the highest of cost for employers.

Adapted from: Employee Benefit Advisor (July 18, 2018) - Cort Olsen, Associate Editor

The number of million-dollar medical claims has nearly doubled, with cancer care remaining the most costly health condition, according to a new Sun Life Financial report.

Cancer made up $798.7 million in reimbursements to self-funded employers from 2014 to 2017, followed by metabolic disorder and hemophilia disorder, according to Sun Life’s 2018 High-Cost Claims Report.

The report, based on analysis of Sun Life’s database of over 62,000 medical stop-loss claimants, shows that high-cost conditions totaled $6.9 billion in paid charges over the four-year period.

The number of patients with million dollar claims rose 87%, to 194 in 2017 from 104 in 2014, with most charges ranging from $1 million to $1.5 million, and totaling over $935 million in charges.

The growth in million-dollar claims can be expected to expand further due to new life-saving treatment options coming to market, along with existing treatments getting approved for expanded use.

“This means better care and outcomes for patients,” says Dan Fishbein, president of Sun Life Financial, who notes that the trend is an important consideration for employers who self-fund their medical plans. “We partner with our clients to protect them from the financial risks of these high-dollar claims, but also to work with them to identify opportunities for cost savings that may improve patient care as well.”

Also see: “ In a broken healthcare system, an adviser offers custom medical plans ”

Other analysis from the report showed that rare conditions hit highest dollars. The two highest claims for a patient in a single policy year were for metabolic disorder in 2016, with a total of $6.7 million in treatment costs, followed by hemophilia disorder with a total treatment cost of $5 million in 2017.
Million-dollar cases left a big footprint. Patients with claims of more than $1 million represented only 2% of the total number of stop-loss claims from 2014 to 2017, but roughly 20%, or nearly $600 million, of the total $3 billion in stop-loss reimbursement.

White Paper How virtual behavioral healthcare breaks down barriers and increases access to quality care

Employers that offer convenient ways for their employees to identify and treat mental health issues will see healthier employees, decreases in absenteeism and presenteeism, and lower costs as a result of proactively treating the mental health issues that often occur alongside physical conditions.

The impact of injectable drugs peaked in 2017 with four of the five costliest injectable drugs, used to treat cancer or related conditions, accounting for approximately $45 million, or 24% of the total $186.3 million spent that year.

Employers had an 85% chance of seeing a high-dollar claim in any given policy, according to the report. Those who self-insure their health plans use a stop-loss coverage to protect themselves from excessive financial losses from high-dollar claims.

This article originally appeared in Employee Benefit Adviser.

See the full article here: https://www.benefitnews.com/news/million-dollar-medical-claims-increase-by-87

5 Facts on Form 5500

Thu, 10 May 2018 15:50:59 GMT

Large private sector employers who had benefit plans last year should anticipate their annual Form 5500 filing deadlines.

Adapted from: Employee Benefits Corporation (May 10, 2018) - Need to Know Speed Read

Fact #1 | 100+

Filing the Form 5500 is a requirement for private employers who fall under the Employee Retirement Income Security Act ( ERISA ), who have unfunded health and welfare benefit plans with 100 or more participants on the first day of the plan year.

Fact #2 | Health FSA, HRA

Employers who offer Health Care Flexible Spending Accounts ( Health FSA ) under a cafeteria plan, and/or Health Reimbursement Arrangements ( HRA ) in some cases, must file Form 5500. The same rules from Fact #1 apply. It is only required if they have 100+ participants on the first day of the plan year.

Health FSAs and HRAs may be filed as standalone Form 5500s, or may be filed as part of a Wrap plan filing (see Fact #3 for more). Schedule A is not required for Health FSA and HRA plans.

Fact #3 | Fully-Insured or Self-Funded Insurance Plans

One, or many? For each fully-insured or self-funded benefit plan an employer offers, the employer must file a separate Form 5500.

Employers can also choose to file just one Form 5500 by using one wrap plan for multiple benefit plans. (A wrap plan document and SPD are required for this type of filing.)

Fact #4 | Deadlines

Calendar-year plans : The many employers with plans that ended December 31, 2017 should be aware that their Form 5500 deadline is July 31, 2018 .

General due date for other plans: The exact Form 5500 filing deadline for any benefit plan is the last day of the seventh month following the last day of the plan year.

Fact #5 | Extensions

Employers can file for an extension of up to 2 ½ months on or before their Form 5500 deadline, by using IRS Form 5558.

Want more facts and information about Form 5500s requirements? Please see the Compliance Buzz article " Form 5500 Filing Tips-Who, When, What, How? ".

IRS Updates Decision on 2018 HSA Limits

Mon, 30 Apr 2018 16:13:51 GMT

The 2018 HSA family contribution limit is back to $6900

Adapted from: OPTUMBank 2018

On April 26th, the IRS updated its decision to decrease the 2018 maximum contribution limit for family coverage only. The maximum annual contribution limit for family coverage limit is now back to $6,900.

Earlier this year, the IRS had adjusted the maximum contribution limit for family coverage from $6,900 to $6,850. Yesterday the IRS updated its decision. To view the official IRS announcement, please visit the Internal Revenue Service press release .

In response to the IRS update, Optum Bank has updated its systems to ensure compliance with the IRS updated decision for its clients and account holders.

In addition, Optum Bank plans to notify account holders by email next week on the IRS updated decision for the 2018 annual maximum contribution limit for family coverage and has posted the alert to the optumbank.com website.

Here are up-to-date 2018 contribution limits:

• $6,900 for family coverage
• $3,450 for individual coverage

Note: There is no change for the individual coverage annual contribution limit

Health Care Reform Alert

Fri, 27 Apr 2018 19:36:55 GMT

Infomed on Reform - Adapted from Cigna (April 11, 2018)

Adapted from Cigna - April 11, 2018

Final Regulations – 2019 Notice of Benefit and Payment Parameters

On April 9, 2018, the Department of Health and Human Services (HHS) issued final regulations and related guidance on Affordable Care Act (ACA) provisions including Essential Health Benefits (EHBs), out-of-pocket (OOP) maximums, and Marketplace updates and reforms. These regulations, generally effective for plans and plan years beginning on and after Jan. 1, 2019, largely mirror the proposed regulations issued Oct. 27, 2017.

The final rule affords greater flexibility to states for determining EHBs, reduces some regulatory requirements in the individual and small group markets and provides annual benefit provision updates. Additional guidance expands the individual mandate hardship exemptions available for 2018 for people living in states with federally-facilitated Marketplaces.

While the EHB benchmark plan changes most directly impact individual and small group plans, they will affect large group health plans as well. Otherwise, the final regulations are primarily focused on individual and small group Marketplace updates and reforms.

Essential Health Benefits (EHBs)
For plan years beginning on and after Jan. 1, 2020, the final rule allows states greater flexibility in selecting EHB benchmark plans. States are allowed to follow current rules and maintain 2017 benchmark plans, or they may select a new EHB benchmark plan annually from one of the following three options:

· Choose another state’s 2017 benchmark plan – allows states to select another state’s 2017 benchmark plan, and implement the plan benefits and limits to their own EHB standards, such as changing benefits with dollar limits to non-dollar limits.

· Replace one or more of the 10 required EHB categories of benefits under its current 2017 benchmark plan with the same categories from another state’s 2017 benchmark plan – giving states the ability to make precise changes to their 2017 benchmark plans at the coverage detail level. For example, State A may select the prescription drug coverage EHB from State B, which uses a different drug formulary.

· Otherwise select a new set of benefits to become its benchmark plan – provided the plan meets other specified requirements.

The three options are subject to additional requirements, including two scope of benefits conditions. States must affirm that their new/modified benchmark plan provides a scope of benefits that is equal to, or greater than, the scope of benefits provided under a “typical employer plan,” and is no more generous than the most generous of a set of comparison plans. HHS released final guidance with the methodology states can use for comparing benefits. States have until July 2, 2018 to submit their 2020 EHB benchmark plan to the Centers for Medicare and Medicaid Services (CMS).

As a reminder, any health plan that covers EHBs must cover these benefits with no annual or lifetime dollar maximums. This includes both fully-insured and self-funded employer-sponsored plans.

2019 out-of-pocket (OOP) maximums
The 2019 OOP maximums increase to $7,900 for individual coverage and $15,800 for family coverage. These coverage limits apply to all non-grandfathered plans, regardless of size or funding type.

Marketplace regulations
The final rule also includes a number of provisions (effective Jan. 1, 2019) intended to strengthen the Health Insurance Marketplace, including:

· Deferring the network adequacy reviews for qualified health plan (QHP) certification to the states

· Loosening the audit process for agents, brokers and issuers who participate in the direct enrollment process

· Updating the risk adjustment model for insurers with high-cost enrollees

· Modifying the requirements for Marketplaces to verify eligibility for, and enrollment in, qualifying employer-sponsored coverage

· Not specifying 2019 standardized plan options (known as simple choice plans)

· Updating special enrollment period (SEP) rules for coverage effective dates specific to SEPs that allow adding or changing dependents

· Adding a new SEP for pregnant women who were receiving coverage through the Children’s Health Insurance Program (CHIP) but lose that access

· Allowing Marketplaces to determine individual affordability exemptions based on affordability of the lowest-cost metal level plan available

· Allowing enrollees to request same-day termination of coverage

· Removing several Small Business Health Options Program (SHOP) requirements for online enrollment

Other market reforms
In addition to Marketplace updates, the final rules also modify other ACA provisions, including:

· Streamlining the rate review process for states and issuers, including when rates are posted by the states, increasing the threshold at which rate increases require review from 10% to 15%, and establishing a process for states to request a higher threshold

· Modifying the Medical Loss Ratio (MLR) rules, including simplifying quality improvement activity reporting requirements for issuers and establishing a process for states to use to request adjustments to the 80% MLR standard in the individual market

Review the information at these links for additional details:

· Read the Final Regulations

· Read the HHS Fact Sheet , which summarizes the regulations

Expanded individual mandate hardships
On April 9, 2018, HHS also issued guidance that expands individual mandate hardships. These additional circumstances are available to individuals who live in states that have federally-facilitated Marketplaces. While the individual mandate is effectively repealed beginning Jan. 1, 2019 due to the zeroing out of the penalty, eligible individuals may claim these hardships for the current calendar year or up to two years prior.

New hardship exemptions include people who:

· Live in a county, borough, or parish in which no QHP is offered

· Live in a county, borough, or parish in which there is only one issuer offering coverage and can show that the lack of choice resulted in them failing to obtain coverage under a QHP.