On March 5, 2014, the White House announced a two-year extension to the previously announced one-year transition relief allowing individual and small group insured members to “keep the plans they liked”. In other words, delay the implementation of several Affordable Care Act (ACA) provisions for another two years. This extension is subject to the same stipulation affecting the initial one year delay announced on 11/14/13, which is that both insurers and States must allow and approve of the relief/delay.
IMPORTANT: On March 24, 2014, Bruce R. Jamge, CPCU, CIE, Nebraska;s Director of Insurance, issued a notice which indicated, in part – “…
Anyone that has ever played the game Jenga or any other stacking game appreciates the challenge, if not the risk, associated with removing individual pieces of a constructed mass. If just a single piece is yanked out of the construct, the entire design crashes down, leaving a mess of pieces, and nothing resembling the original design. Approaching its 4th anniversary, the Affordable Care Act (ACA), or Obamacare, is gradually turning into a great big game of Jenga! Ironically, a law that was passed on a 100% partisan, party-line basis is now being attacked directly and indirectly, from both sides of the aisle, democrat and republican alike.
Last week (March 5, 2014), the IRS and the Department of Treasury (DOT) released FINAL rules related to some very important Affordable Care Act (ACA) requirements addressing health insurance plan reporting. These reporting requirements (originally set to take effect at the end of this year, but delayed one year along with the employer mandate) affect employers with 50 or more full-time employees (including full-time equivalents) starting in early 2016 for plans in force during the 2015 calendar year (regardless of anniversary or ERISA plan date). Reporting is voluntary for 2014/2015, although it might not be a bad idea to consider a “dry run” in preparation for the 2016 requirement.
Ordinarily, this blog addresses current events in the health insurance and health care spaces. But this week I’m making an exception and informing about a provision of the Affordable Care Act (ACA) that is not set to take effect until 2018. Many of the clients, colleagues, friends and audiences I encounter are talking (if not worrying) about the so called Cadillac tax…now!
Accordingly, this week;s post is meant to provide some background on this provision, if not for those merely worrying about it, but for those that are long term planners. Please keep in mind that final regulations addressing the Cadillac tax have not been released to date. Here is what we know…
Last week (02/20/2014), the ACA’s “trinity” of compliance and enforcement (i.e., departments of Health/Human Services; Labor; Treasury) jointly issued both FINAL and PROPOSED regulations pertaining to the ACA provision addressing new hire waiting period limitations. This week's post will focus primarily on the FINAL regulations.
Let me start by defining what it is that we received guidance on – the so called “90 day waiting period limitation”. The waiting period is the period of time allowed to pass before health insurance coverage can become effective for an otherwise eligible employee (and his/her dependents).
There is an old expression – “Figures don’t lie, liars do figure”. We all rely on data for various purposes, and the health care industry is no exception in its use of data to explain, defend, describe, or refute various measures. In fact, there is a relatively quiet movement underway to establish health care standards to better enable providers to utilize a standardized, “best practices” method of delivering care. If you want to understand this movement better, google – “patient centered outcomes research institute” or PCORI, and check it out. (By the way, the Affordable Care Act (ACA) requires health insurers and self funded plans to fund the PCORI at a rate of $2 per insured member per year in 2014.)
This past Monday (February 10, 2014) the Treasury Department issued long awaited FINAL REGULATIONS pertaining to the Affordable Care Act’s (ACA) “employer mandate”, aka “employer shared responsibility”; or “pay or play”. There is a great deal of information and guidance contained in these regulations, thus, I will not attempt to address all of it in this post. Rather, I’ll provide some of the highlights, and embed some links to direct you to more comprehensive details.
It is imperative that readers/stakeholders understand there are two (2) aspects to this release:
1. A delay of the employer mandate for otherwise affected employers with 50-99 full-time employees until – “the first plan year beginning on or after JANUARY 1, 2016”.
From the time the Affordable Care Act (ACA) was signed into law on March 23, 2010, after having been passed by congress on a 100% partisan basis by the Democrat party, the Republican party has largely expressed opposition to the law. In fact, the Republican controlled House of Representatives has passed upwards of 40 bills seeking to completely repeal the ACA. However these bills never made it to the Democrat controlled Senate floor for a full vote, and thus “died on the vine”. Perhaps no other issue facing our country has seen the level of opposition and discourse than has health care “reform”.
These are three (3) of the more than 18 new taxes, fees, and deduction changes that have been created/implemented in order to fund the Affordable Care Act (ACA), aka Obamacare. The later two (2) have not yet been imposed/collected, but the bell rings this year (2014) for their collection and remittance to Uncle Sam. This week I thought I would delve into the ear marking of some of this revenue, and what many are calling the ACA’s “insurance company bailout”.
The ACA contains three (3) separate and distinct “bailout programs” embedded within it’s 2,700 pages. They are the Reinsurance Program (temporary), Risk Adjustment Mechanism,
Happy New Year to all my friends, colleagues, and subscribers throughout the land! As you may have noticed, this blog went dormant over the holidays, which was as much a relief for my readers; I’m sure, as it was for me. So now here we are in 2014, and back to business, and weekly blog posts!
I thought I’d start the new year off with a brief update on what’s happening with the public health insurance marketplaces/exchanges. Last month involved a flurry of activity, guidance and extensions announced just prior to the holidays. Here’s the latest;
