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 22, 2014

IRS Releases Notice 2014-55 Providing for Additional Election Changes Events (Cafeteria Plan)

The IRS released Notice 2014-55 which provides additional permitted election changes for health coverage under Code Section 125 cafeteria plans. This notice provides two specific situations in which a cafeteria plan participant may wish to revoke, during a plan year, the employee's election for employer-sponsored health coverage under the cafeteria plan in order to purchase a Qualified Health Plan through a Marketplace.

Tuesday, August 5, 2014

IRS Increases ACA's Affordability Percentages for 2015

On July 24, 2014, the IRS released Revenue Procedure 2014-37 to index the Affordable Care Act's (ACA) affordability percentages for 2015 under the employer mandate. The IRS also adjusted upward the income level under which employees are exempt from the ACA's individual mandate.

Employer Mandate Adjustment
An applicable large employer's health coverage will be considered affordable for plan Years beginning in 2015 under employer mandate if the employee's required contribution to the plan does not exceed 9.56 percent of the employee's household income for the year, up from 9.5 percent. This increase also applies to the three safe harbors that the IRS created in the regulations.

The reason for the increase is that the employer mandate was originally meant to take effect in 2014 but was subsequently delayed until 2015 or 2016, depending on employer size.

Individual Mandate Adjustment
Revenue Procedure 2014-37 also adjusts the affordability percentage for the exemption from the individual mandate for individuals who lack access to affordable minimum essential coverage. For plan years beginning in 2015, coverage is unaffordable for purposes of the individual mandate if it exceeds 8.05% of household income (as opposed to 8% originally).

This change stems from the requirement that the IRS must adjust the affordability percentage to reflect the excess of the rate of premium growth over the rate of income growth for the preceding calendar year, with each subsequent plan year being adjust accordingly.

For a copy of Revenue Procedure 2014-37, please click on the link below:
http://www.irs.gov/pub/irs-drop/rp-14-37.pdf

Monday, June 30, 2014

Justices: Can’t make employers cover contraception

WASHINGTON (AP) — The Supreme Court ruled Monday that some corporations can hold religious objections that allow them to opt out of the new health law requirement that they cover contraceptives for women.

The justices’ 5-4 decision is the first time that the high court has ruled that profit-seeking businesses can hold religious views under federal law. And it means the Obama administration must search for a different way of providing free contraception to women who are covered under objecting companies’ health insurance plans.

Contraception is among a range of preventive services that must be provided at no extra charge under the health care law that President Barack Obama signed in 2010 and the Supreme Court upheld two years later.

Two years ago, Chief Justice John Roberts cast the pivotal vote that saved the health care law in the midst of Obama’s campaign for re-election. On Monday, dealing with a small sliver of the law, Roberts sided with the four justices who would have struck down the law in its entirety.

HHS To Allow Automatic Re-Enrollment Under ACA

The majority of those who enrolled in the Patient Protection and Affordable Care Act plans through the exchanges will be auto-enrolled in the same health plan they selected in 2014 this coming enrollment period, as well as receive the same subsidies, if applicable, the administration said Thursday.

The rule was proposed by the Centers for Medicare and Medicaid Services.

“As we plan for open enrollment in year two and continue to build a sustainable long-term system, we are committed to simplifying the experience for consumers by allowing auto-enrollment,” HHS Secretary Sylvia Mathews Burwell said in a news release. “We are working to streamline the process for consumers wishing to remain in their current plan.”

Basically, under the new guidelines, most of the law’s customers “would be able to renew subsidized health insurance coverage without filing an application and without going back to HealthCare.gov, the website that frustrated millions of consumers last fall.” New HHS Secretary Sylvia Mathews Burwell, who issued the rules Thursday, said, “We are working to streamline the process for consumers wishing to remain in their current plan.”


Health Reform Questions - Reimbursing Individual Market Premiums

Question: Can an employer reimburse its employees for premiums on a pre-tax basis for purchasing individual market medical coverage?

Answer: No. In IRS Notice 2013-54 & Technical Release 2013-3, the IRS and DOL prohibit the reimbursement of premiums for individual medical policies from health reimbursement arrangements and premium only plans.

Recently, the IRS issued a Frequently Asked Questions (FAQ) list that reiterates earlier guidance disallowing pre-tax employer reimbursements for employee health care premiums. The FAQ also calls attention to the $100 per day, per employee penalty for non-compliance.

Do You Speak Healthcare?

Do You Speak Healthcare?

If you do an Internet search for the acronym, ACA, you are likely to find over 200 possible definitions. (I found 213 on one page alone!)

When referring to ACA in the healthcare industry, ACA stands for the Affordable Care Act, commonly referred to as Obamacare. ACA is just one of the newer acronyms that you hear in the healthcare industry. ACO, CIN, and PCMH are also newer terms that you will begin to hear more about.

ACO stands for Accountable Care Organization. A CIN is a Clinically Integrated Network and a PCMH is a Patient Centered Medical Home. All of these are clinical models in the healthcare industry designed to improve the health outcomes of the patients and members that they serve.

Want to learn more? We can help you navigate the ACA, CIN, EOB, and SBC of it all!

View a Glossary of Common Healthcare Words as well as Abbreviations and Acronyms

Article courtesy of Optima Health.

Monday, May 5, 2014

Administration announces proposal to clarify availability of Health Insurance Marketplace coverage to workers eligible for COBRA

On May 2, 2014, the Obama administration announced updates to model notices informing workers of their eligibility to continue health-care coverage through the Consolidated Omnibus Budget Reconciliation Act. The updates make it clear to workers that if they are eligible for COBRA continuation coverage when leaving a job, they may choose to instead purchase coverage through the Health Insurance Marketplace.

“In many cases, workers eligible for COBRA continuation coverage can save significant sums of money by instead purchasing health insurance through the Marketplace,” said Assistant Secretary of Labor for Employee Benefits Security Phyllis C. Borzi. “COBRA continues to play an important role in helping workers and families maintain coverage after a job loss, and it is important that workers know that in some cases there is a Marketplace option as well.”

Tuesday, April 22, 2014

Protect your Marketplace Account - Change your password

Recently, you may have heard about a new internet security weakness, known as Heartbleed, which is impacting some websites. HealthCare.gov uses many layers of protections to secure your information. While there’s no indication that any personal information has ever been at risk, we have taken steps to address Heartbleed issues and reset consumers’ passwords out of an abundance of caution. This means the next time you visit the website, you’ll need to create a new password. We strongly recommend you create a unique password – not one that you’ve already used on other websites.

Friday, April 4, 2014

Grace Period Provided for Payment of Premiums

Question: Must health plans participating in the exchanges provide individuals who purchase subsidized insurance coverage through the exchanges a 90-day grace period before terminating the coverage for non-payment of the premiums?

Answer: Yes. Under 45 CFR 156.270, individuals who purchase subsidized coverage through the exchanges must be provided a 90-day grace period before their coverage is cancelled for non-payment.

Wednesday, April 2, 2014

New Law Repeals Deduction Limits for Small Employer Insured Health Plans

On April 1, 2014, President Obama signed the "Protecting Access to Medicare Act of 2014" into law. The new law mainly focuses on Medicare reimbursement rates for doctors. A small, easily-overlooked provision of the law retroactively eliminates the Affordable Care Act's (ACA) annual deductible limit for health plans in the small group market.

Thursday, March 13, 2014

Health Insurance Open Enrollment Ends March 31


If you are seeking health coverage through the Health Insurance Marketplace, be sure to apply before the end of the open season on March 31, 2014.

If you haven't enrolled by March 31, you won't be able to apply until the next open season, unless you qualify for a special enrollment period. The next open enrollment is proposed to run from November 15, 2014 through January 15, 2015.

There's no limited enrollment period for Medicaid or the Children's Health Insurance Program (CHIP) -- you can enroll at any time.

Monday, March 10, 2014

Final 2015 Notice of Benefit and Payment Parameters and Actuarial Value Calculator

On March 6, the Department of Health and Human Services (HHS) provided the 2015 actuarial value calculator and issued final regulations on the 2015 Notice of Benefit and Payment Parameters. While HHS changed a few items from the proposed rule – namely the open enrollment period and cost-sharing limits – many provisions remain the same.

Open Enrollment Period
The 2015 open enrollment period for individual and family plans has been extended by 30 days and will be held November 15, 2014 – February 15, 2015.

2015 Cost-Sharing Limits
The 2015 maximum annual out-of-pocket limits for all non-grandfathered plans will increase by 4.21 percent, lower than originally proposed. The confirmed 2015 amounts are $6,600 for individual coverage and $13,200 for family coverage. The maximum 2015 deductibles for insured non-grandfathered small group plans are $2,050 individual and $4,100 family.

Statement Of The Virginia Bureau Of Insurance Regarding Further Extension Of Individual And Small Group Health Insurance Plans

On March 5, 2014, the Obama Administration proposed a further suspension of the enforcement of certain provisions of the federal Affordable Care Act (ACA) and urged state insurance regulators to allow health insurance carriers to offer renewal of certain non-ACA compliant health insurance plans such that they could remain in effect into 2017.

Following this announcement, the State Corporation Commission's Bureau of Insurance (Bureau) has undertaken a legal and regulatory analysis of the extension proposal.

Virginia state insurance laws were changed to conform to various provisions of the ACA effective January 1, 2014. Therefore, in the absence of specific authorization by the General Assembly, insurance carriers remain subject to conforming Virginia law.

The Bureau previously encouraged carriers to offer policyholders the opportunity to "early renew" their existing insurance plans before January I, 2014, when the new Virginia provisions became effective. This allowed policyholders to continue existing coverage into 2014.

Policyholders with non-ACA compliant policies expiring in 2014 are advised to evaluate all available options tor health insurance coverage in 2014 to replace their coverage that may be expiring due to implementation of the ACA and conforming Virginia law.

Friday, March 7, 2014

Transitional Relief Extended through 2016

When the Obama Administration announced the transitional relief policy that allows individual and small group, fully insured, non-grandfathered policyholders to maintain their 2013 medical coverage through 2014, it indicated it would assess the policy and the specified timeframe.

The Centers for Medicare and Medicaid Services (CMS) issued a memo that it will extend the transitional policy for two years, for policy years beginning on, after or before Oct. 1, 2016, with the possibility of adding a one year extension then, if appropriate.

The transitional relief also applies to large businesses that currently purchase insurance in the large group market if, as of Jan. 1, 2016, they will be redefined by the Affordable Care Act (ACA) as small businesses purchasing insurance in the small group market.

As with the earlier transitional relief policy, State governments and health insurance issuers will have the option to offer the transitional relief or not participate.

Wednesday, February 12, 2014

Employer Mandate Delayed for some Employers

On February 10th, 2014, the Obama administration announced that it would postpone enforcement of a federal requirement for medium-size employers to provide health insurance to employees and allow larger employers more flexibility in how they provide coverage.

The "employer mandate," (also known as the “Play or Pay” requirements) which was originally supposed to take effect last month, had already been delayed to January 1st, 2015, and now the administration says that employers with 50 to 99 employees will not have to comply until 2016.

In addition, the requirement would be put into effect gradually for employers with 100 or more employees. Employers in this category will need to offer coverage to 70 percent of full-time employees in 2015 and 95 percent in 2016 and later years, or they will be subject to tax penalties.

Please review the attached Health Care Reform Hot Topic for more information. 
Highlights:
  • No mandate for small group employers (2-50) is scheduled at this time.
  • Compliance for medium-sized group employers (50-99) is delayed until 2016.
  • Compliance for large-sized group employers (100+) is still delayed until 2015.
  • Certain 2014 transition relief is extended, including relief for non-calendar year plans.
  • The requirement to offer coverage to 95 percent of full-time employees will be phased in over two years.
  • Full-time status is clarified for certain groups.

Friday, January 24, 2014

IRS to propose rules clarifying ACA penalties

The Internal Revenue Service has drafted a collection of proposed regulations that could determine whether some taxpayers will owe fines for failing to get health coverage.

The individual mandate section in the Patient Protection and Affordable Care Act requires some taxpayers who fail to own a minimum amount of major medical coverage, or “minimum essential coverage,” to pay the fines.

Some sections in the proposed IRS regulations will exempt some people in limited-benefit government programs from paying the fines.

Those affected include state programs for the medically needy, Medicaid pilot programs, and two programs that give people some access to military health care services.

The IRS assumes many enrollees are confused.

HHS Releases 2014 Federal Poverty Level Guidelines

HHS has released 2014 federal poverty guidelines.  Updated annually for inflation, the 2014 guidelines will set the income thresholds for subsidy eligibility on exchanges for 2015. The threshold (in the 48 contiguous states and DC) for one person will be $11,670, an $180 increase over the 2013 level.  An employee's receipt of exchange subsidies could trigger an employer shared responsibility penalty starting in 2015.  IRS proposed rules include an employer affordability safe harbor based on the federal poverty level.

Monday, January 20, 2014

Rules on equal coverage delayed

WASHINGTON (Reuters) - The Obama administration is delaying enforcement of a provision of the new healthcare law that prohibits employers from providing better health benefits to top executives than to other employees, the New York Times reported on Saturday.

Tax officials said they would not enforce the provision this year because they had yet to issue regulations for employers to follow, according to the Times.

Internal Revenue Service spokesman Bruce Friedland said employers would not have to comply until the agency issued regulations or other guidance, the newspaper reported.

The IRS was not immediately available to confirm the Times story.

The rollout of the Affordable Care Act, known as Obamacare, has been marked by a number of delays in implementing certain parts of the law. In November, the administration announced a one-year delay in online insurance enrollment for small businesses.

Thursday, January 16, 2014

U.S. judge upholds subsidies pivotal to Obamacare

WASHINGTON (Reuters) - A judge on Wednesday upheld subsidies at the heart of President Barack Obama's healthcare overhaul, rejecting one of the main legal challenges to the policy by conservatives opposed to an expansion of the federal government.

A ruling in favor of a lawsuit brought by individuals and businesses in Texas, Kansas, Missouri, Tennessee, West Virginia and Virginia would have crippled the implementation of the law by making health insurance unaffordable for many people.

In his ruling, U.S. District Judge Paul Friedman in Washington D.C. wrote that Congress clearly intended to make the subsidies available nationwide under the 2010 Patient Protection and Affordable Care Act.

Tuesday, January 14, 2014

Marketplace Enrollment Numbers

The U.S. Department of Health and Human Services released the most detailed information on people who enrolled in health plans through either the federally run marketplace or exchanges operated by 15 states and the District of Columbia.

Almost 2.2 million people enrolled in health plans through Dec. 31 in the federal and state marketplaces. (No data has been released on how many enrollees have secured their enrollment with their first premium payment.) Most residents enrolled in December.

Of the almost 2.2. million: