The folks at KFF (a nonprofit organization based in San Francisco, CA) have done a phenomenal job of collecting and posting over 300 FAQs pertaining to the 6th annual upcoming Affordable Care Act (ACA/ObamaCare) open enrollment period. New questions and answers have been added expanding upon the already rich library of detail pertaining to the ACA and specifically open enrollment. This set of FAQs are searchable and cover not only ACA but the health insurance marketplace in general. The details provided will be a very valuable resource to any consumer, navigator, broker and all those that have a vested interest in the marketplace.
Search the FAQs
The database of information covers topics including eligibility, requirements and general information about State ACA marketplaces. The collection also addresses the 2019 repeal of the individual mandate penalty and offers a totally new section on short-term health insurance policies.
Site visitors will be able to obtain information on situations that affect all people from young adults to retirees. Immigrant situations and folks with job-based plans will also find information to help them make the important decisions needed in this next enrollment period. We were pleased to also see that over 150 of the FAQ’s are also available in Spanish.
Please note that open enrollment for the Federal and most state marketplaces begins on Thursday November 1, 2018.
The KFF website also provides many other resources including:
As always, we are here to help you navigate these waters. Many of your questions will be answered by searching through this valuable database. However, each situation is unique. Please contact us if you would like to discuss the upcoming enrollment period or any topic related to your business’ health care solution.
In a recently updated article from the Kaiser Family Foundation, the authors continue to monitor insurer’s Affordable Care Act (ACA/ObamaCare) marketplace filings by State. These filings detail premiums the marketplace insurers will be charging in the areas where they plan to participate in 2019. The State or the Federal Government reviews each of these premium rates to ensure that they are both accurate and justifiable before they go into effect. There are different criteria used by State and each State varies on how much information they release.
The KFF analysis compares and contrasts various levels (bronze, silver and gold) of the ACA across the 50 States and the District of Columbia. The authors will continue to update this report as additional States release or update their reviews. It is likely that the information will change over the remainder of 2018.
The authors note:
“The second lowest-cost silver plan serves as the benchmark for premium tax credits (which subsidize premiums for low and modest income exchange enrollees) and is the only plan that offers reduced cost sharing for lower-income enrollees. About 63% of marketplace enrollees are in silver plans this year, and 29% are enrolled in bronze plans.”
The insurers that participate in the various States are mostly taking into account the repeal of the individual mandate (associated with the tax cut in December 2017) that goes into effect this coming year. It is also anticipated that there will be an increase in non-compliant, short-term, limited duration health plan (STDL). Without the penalty, it is expected that relatively healthy individuals will leave the regulated insurance marketplace and thereby cause an increase in the 2019 premiums. It is unsure if all the providers have fully included this information in their 2019 estimates.
The authors also include:
“Additionally, the Trump administration decision to stop making cost-sharing reduction payments to insurers had an upward effect on 2018 premiums, but some insurers may adjust premiums in 2019 up or down if their 2018 adjustments proved to be inaccurate. Some insurers may be changing which plans are subject to increased premiums to compensate for the loss of cost-sharing reduction payments. In 2018 many insurers increased premiums just on silver marketplace plans – which are the only plans in which consumers can receive cost-sharing reductions — but a small number of states directed insurers to increase individual market premiums across the board.”
How was the data collected?
The authors collected data from health insure filings to the various States released by the State’s Insurance Departments. The submissions were public and available for the States they investigated. The data focuses on major cities and larger communities where insurance providers participate. Some of the plans may not be available in all cities or counties within the individual rating areas. Rating areas are defined as groups of adjacent counties and the analysis chose a represented sample within each area.
As always, if you have any questions or comments with what this means for your business, please contact us.
Source: Kaiser Family Foundation
Details are being released regarding the number of individuals that signed up for medical coverage under the Affordable Care Act (ACA) Marketplace. The numbers show that there is an overall reduction of 3.7% in 2018 over 2017. This a combination of a slight increase (0.2%) in the state-based marketplace offset by a reduction at Healthcare.gov. There were 15 states that showed an increase over 2017 with the majority of these being state-based services.
This is a larger enrollment than many expected because funding for outreach informing those potentially in need of the program was dramatically reduced and the enrollment period was cut in half. There were also a few political factors including the government’s termination of the cost-sharing provision and uncertainty whether the law would be in effect at all.
Outreach, as outlined in the ACA, was provide through Navigator programs. These programs helped inform and guide potential enrollees in the 34 states using Healthcare.gov about enrollment periods and what they specifically had to do to comply with the ACA. In august of last year, the Center for Medicare and Medicaid Services significantly reduced their spending on Navigator. Because it was so close to the actual enrollment period, many thought that it would have a major impact on enrollment in general.
The elimination of the cost-sharing provision for insurers prior to the open enrollment period led to an increase in the premiums that many would have to pay. It also increased the premium subsidies for some of those enrolled that qualified leading to reductions in what they had to pay.
In Illinois, 334, 979 enrolled this year down 6% from the 356,403 that enrolled in 2017.
There are still many changes on the horizon with regards to the ACA and its components. While Congress did not fully repeal and replace the ACA, they did remove the individual mandate as part of the most recent tax bill. The full impact of this will be realized over the next few months and years.
We will continue to monitor progress in the provisions of the ACA and how it will impact your business. Please contact us if you would like to discuss how this changing environment will impact your business and what steps you can take to make sure that you are compliant while still saving as much on the expense side as possible.
Sources for this blog include:
Kaiser Family Foundation
The Internal Revenue Service (IRS) recently released Revenue Procedure 2017-36 which provides indexing adjustments for certain provisions under the Patient Protection and Affordable Care Act (ACA/Obamacare). Of interest to employers is the index adjustment of the contribution percentage used for purposes of determining affordability under the employer shared responsibility (pay or play) mandate. Employers looking to avoid pay or play penalties will need this information to assist in the decision-making process relative to plan designs and employer funding.
Background on Indexing Adjustments
In order to avoid pay or play penalties, applicable large employer (ALE) members must offer full-time employees minimum essential coverage (MEC) that is both affordable and provides minimum value (i.e., actuarial value of at least 60%). Under applicable rules, health care coverage is affordable if the employee’s required contribution for the lowest cost self-only option offered by the employer is 9.5% (as adjusted annually) or less of the employee’s household income. The statute defines “household income” as the modified adjusted gross income of the taxpayer and the members of the taxpayer’s family, and modified adjusted gross income is defined as adjusted gross income plus certain types of income that would otherwise be excluded from the taxpayer’s income (i.e., foreign earned income and housing costs, tax exempt interest, and the excludable portion of the taxpayer’s social security income).
The IRS did not address the household income standard in its employer shared responsibility regulations.
The IRS did not address the household income standard in its employer shared responsibility regulations. Instead, the IRS established a choice of three safe harbors that employers could use to demonstrate compliance with the affordability standard, all of which limit the determination of affordability to employee self-only coverage. Those safe harbor affordability standards include the Form W-2 Safe Harbor (based on the employee’s W-2, Box 1 reported wages for that year), the Rate of Pay Safe Harbor (based on an employee’s hourly rate times 130 hours per calendar month), and the Federal Poverty Line Safe Harbor (based on the annual federal poverty line for a single individual divided by 12).
The provision in the ACA/Obamacare statute that established 9.5% of an employee’s household income as the general affordability standard also provided for indexing (adjustments) of that standard beginning in 2015. The annual adjustments, prior to 2018, are as follows:
- 2015 – 9.56%
- 2016 – 9.66%
- 2017 – 9.69%
- 2018 – 9.56% (decreased)
Affordability percentage for 2018
For purposes of the employer shared responsibility mandate, the required contribution percentage has decreased for 2018 to 9.56% (from 9.69% in 2017). This means that if an employee’s share of the premium (in 2018) for the lowest cost self-only option offered by the employer is more than 9.56% of his or her household income (or the applicable standard if using one of the affordability safe harbors), the coverage is not considered affordable for that employee and the ALE member may be liable for a penalty if that employee obtains a premium tax credit for health coverage purchased through the public exchange.
So, unless the employer shared responsibility mandate (or at least the related penalties) is repealed, employers may need to reduce employee contributions (or the relative share of plan cost reflected in employee contributions) in 2018 to maintain “affordable” coverage under the ACA/Obamacare.
Contact us for more details
The article by Katie Kuehner-Herbert linked below highlights several elements from the Large Employers’ 2018 Health Care Strategy and Plan Design Survey.
The health care industry is rapidly changing. Daily we hear of something new. We see changes in Washington, at the State levels and even some changes locally. The costs of supplying health care to employees for the average business is growing well beyond the rest of the business. To help combat this trend, we are starting to see businesses leverage new means for controlling costs and steer away from the traditional ways of the past. It is a fine line to walk down. As a business, cost containment is paramount. With employee acquisition and retention, having a quality health care plan in place is crucial. We need to find a way to keep costs and care in balance so that neither have a negative impact on the business.
Key Highlights from the 2018 Heath Care Strategy Survey include:
- Implementation of consumer-directed health plans.
- Exploring new ways to guide employees through the systems.
- Offering consumer-directed health plans.
- Raising awareness and management of pharmaceutical costs.
- Engaging telehealth services when state law allows.
- Promoting accountable care organizations.
- Supporting on/near site health centers.
- Utilizing centers of excellence for certain procedures.
This is a focused article that gets to the heart of what many businesses need to consider as we move together towards a very uncertain and potentially very costly future. For more ways to control rising health care costs, please contact us.