At Sterling Benefits, we are proactively working with multiple resources to dissect the various facets of the law and to understand the guidelines and timelines it presents to our clients. You can expect that we will provide ongoing communications and information as interpretation and implementation details continue to unfold from the government.

Our priority at Sterling Benefits is to stay focused on delivering value and quality customer service to our customers as we work together with health care reform. Significant changes will take place in 2014. In the meantime, there are some items that will require attention much sooner. We will keep you posted as details and clarifications from the government are made available. We encourage you to review this information and utilize our office as a resource in addressing questions and concerns.

Monday, September 30, 2013

Animation Explains Changes Coming for Americans Under the Affordable Care Act

2014 is coming--are you ready for Obamacare? Join the YouToons as they walk through the basic changes in the way Americans will get health coverage and what it will cost starting in 2014, when major parts of the Affordable Care Act, also known as "Obamacare," go into effect.

Friday, September 27, 2013

HHS Releases a Report of Health Insurance Marketplace Premiums for 2014

HHS released a report that summarizes the health plan choices and premiums that will be available in the Health Insurance Marketplace. It contains new information, current as of September 18, 2013, on qualified health plans in the 36 states in which the Department of Health and Human Services (HHS) will support or fully run the Health Insurance Marketplace in 2014. Plan data is in final stages but is still under review as of September 18 and may be revised in HHS systems before being displayed for consumers, so this information is subject to change. 

Online enrollment for federal SHOP will be delayed

In the latest setback for the rollout of Obamacare, the U.S. Department of Health and Human Services announced Thursday that small businesses in 36 states can’t enroll their workers into health coverage through the new federally run insurance marketplaces until at least Nov. 1 – one month later than previously announced.

The delay appears to be the result of computer and information technology problems in the Small Business Health Option Program, known as SHOP, an online insurance marketplace specifically for small employers.

Employers still will be able to compare coverage options and begin the application process on Oct. 1, but they won’t be able to sign up workers for coverage until November.

Explanation of Guidance on HRAs, Health FSA- Clarification?

It appears that the pre-tax reimbursement of individual premiums under a premium only plan (POP) (under Code Section 125) is directly at odds with the prohibition against any annual limit on the dollar amount of essential health benefits under the Affordable Care Act (Act). 

On Friday, September 13, the Departments of Labor, Treasury and Health and Human Services provided guidance on the application of certain provisions of the Affordable Care Act (Act) on health reimbursement arrangements (HRAs), certain health flexible spending arrangements (Health FSAs) and employee assistance programs (EAPs). It was clear from the initial reading of the guidance that individual premiums could not reimbursed by HRAs. In a further reading of the guidance, there appears to be more serious consequences.
 

Thursday, September 19, 2013

FTC Alert: Scammers Out to Trick Consumers Using Affordable Care Act

No sooner had the U.S. Supreme Court ruled on the Affordable Care Act than scam artists began working the phones. They say they're from the government and that, using the Affordable Care Act as a hook, they need to verify some information. They might have the routing number from your bank, and then use that information to get you to reveal the entire account number. Or, they'll ask for your credit card or Social Security number, Medicare ID, or other personal information.
 
The Federal Trade Commission, the nation's consumer protection agency, advises consumers not to give out personal or financial information in response to unsolicited phone calls, emails, or knocks on your door. Scam artists want your information to commit identity theft, charge your existing credit cards, debit your checking account, open new credit card, checking, or savings accounts, write fraudulent checks, or take out loans in your name.
  
To avoid scams related to ACA implementation:

Monday, September 16, 2013

DOL Releases Guidance on HRAs, Health FSAs and Certain Other Employer Healthcare Arrangement Options

On Friday, September 13, 2013, the DOL and the IRS issued guidance on how the annual limit and preventive services rules in the Affordable Care Act (ACA) apply to HRAs.

IRS Notice 2013-54 and DOL Technical Release 2013-03 provided much-awaited answers to questions about what types of HRAs comply with these ACA rules. The guidance also addressed Employee Assistance Programs (EAPs). The Notice and Technical Release mirror each other. The guidance applies to plan years starting on or after January 1, 2014. Additional regulatory guidance will be forthcoming.

Thursday, September 12, 2013

DOL FAQ on Notice of Coverage Options

Q: Can an employer be fined for failing to provide employees with notice about the Affordable Care Act's new Health Insurance Marketplace?

A: No. If your company is covered by the Fair Labor Standards Act, it should provide a written notice to its employees about the Health Insurance Marketplace by October 1, 2013, but there is no fine or penalty under the law for failing to provide the notice.
http://www.dol.gov/ebsa/faqs/faq-noticeofcoverageoptions.html

Dear seniors, your Medicare benefits aren't changing under the Affordable Care Act

Dear seniors, your Medicare benefits aren't changing under the Affordable Care Act. That's the message federal health officials are trying to get out to elderly consumers confused by overlapping enrollment periods for Medicare and so-called "Obamacare."

Medicare beneficiaries don't have to do anything differently. Medicare open enrollment starts Oct. 15 and closes Dec. 7, while enrollment for the new state exchanges for people 65 and under launches Oct. 1 and runs through March. 

Next month, roughly 50 million Medicare beneficiaries will get a handbook in the mail with a prominent Q&A that stresses Medicare benefits aren't changing.

AP Article:  http://finance.yahoo.com/news/health-overhaul-confuses-medicare-beneficiaries-141050243.html

Monday, September 9, 2013

Health Insurance Exchange Notices Deadline 10/1/2013

As a reminder …
 
Notices about the health insurance exchanges have to be given to current workers no later than Oct. 1, 2013. Starting Oct. 1, the notices have to be given to new workers on the day they are hired.  
 
The notices must:
  1. tell workers about exchanges, including a description of the services provided and how they can contact exchanges;
  2. let workers know they may be eligible for a premium tax credit if the employer plan’s does not cover at least 60% of the total allowed cost of benefits, and the worker buys a qualified health plan through an exchange;
  3. explain that if the worker buys a qualified health plan through an exchange, he or she may lose the employer contribution (if any) to any health benefit plan the employer offers, and that all or part of the contribution may be excluded from income for federal tax purposes.
The notices (Exchange Model Notices (For Employers who offer a health plan and Employers who do not offer a health plan) and the Revised Model COBRA Election Notice), along with further guidance, can be found at www.dol.gov/ebsa. Please review the attached Health Care Reform Hot Topic for more information on the Model Notices Explanation.

Thursday, September 5, 2013

COBRA and the ACA: Compatible or Irreconcilable?

Several key provisions of the Affordable Care Act (ACA) have now been delayed. When the ACA has fully achieved lift off, what will become of COBRA?
 
The simple answer is that COBRA will continue to fly, until and unless another law permanently grounds it. Here are some observations around the interplay between the ACA and COBRA:
  • The ACA likes COBRA. Parts of the ACA looked to COBRA concepts as the gold standard for calculations. Case in point is W-2 reporting of health care coverage in IRS Notice 2012-09. More recently, the DOL thought COBRA was important enough to update the Model Election Notice when it released the Exchange Notice. Click here for our article.
  • The DOL likes COBRA. Look at this DOL FAQ, which states that the ACA “did not eliminate COBRA or change the COBRA rules.” making it clear that COBRA is not going away. And take a gander at this lengthy 25-year proclamation by the DOL from 2011.
  • COBRA fills some ACA gaps. Granted, the Health Insurance Marketplace will provide COBRA qualified beneficiaries with some alternatives for medical coverage. In some cases, the alternatives may be cheaper, but that is not certain. Also, understand that stand-alone dental, vision, prescription drugs are not required to be offered in the marketplace. Neither are flexible benefits like HRAs and Health FSAs. COBRA offers these benefits to the extent that they are employer-sponsored coverage.
  • To some extent, the marketplace likes COBRA. To some extent, the Marketplace coordinates with COBRA. For example, take your most common reason for termination of COBRA: premium non-payment. If a qualified beneficiary loses coverage because of non-payment, this person is not entitled to a special enrollment period for Marketplace coverage and must wait until the annual enrollment period. Another thing to consider is when the Marketplace opens in 2014, small employers can obtain Marketplace coverage through the Small Business Health Options Program (SHOP). This coverage would be subject to COBRA because it is employer-sponsored coverage.
 
This is COBRA’s current status: a valid law. The ACA did not change COBRA, as the DOL has pointed out.