4 Strategies for Reducing Health Benefits Costs in 2022
Health care costs continue to rise each year, and 2022 will likely be no exception. In the new year, experts predict a 6.5% increase in medical expenses alone, according to Pricewaterhouse Coopers. In terms of health plan premiums, employers anticipate they may rise more than 5% in 2022, a Willis Towers Watson survey reports.
With these increases in mind, employers will want to strategize methods to rein in benefits spending. This article offers four ways to help.
1. Alternative Plan Modeling
One common method for reducing benefits costs is to increase employees’ share of expenses. This could be done directly through premium increases, but that might generate more problems for an employer; after all, many employees are still struggling financially and are ready to leave their jobs for better benefits options thanks to the COVID-19 pandemic.
Considering this, a more careful approach to lowering expenses may be through alternative plan modeling. Instead of a traditional health plan, employers can think about other plan designs that can still benefit employees without excessive costs. Plan modeling alternatives include:
Consumer driven health plan models—High deductible health plans with savings options attached
Self-funding models—Health plans funded and managed by an employer rather than a carrier
Reference-based pricing models—Self-funded health plans with set spending limits on shoppable services
Level-funding models—Self-funded health plans where an employer pays a set amount to a carrier for claims, the remainder of which is refunded at the end of the year if there is any leftover
Each of these plan modeling alternatives has advantages and disadvantages, depending on an organization’s unique circumstances. Employers should reach out to World Insurance Associates, LLC to learn more about the potential of these and other plan models.
2. Health Care Literacy
Improving health care literacy for employees has seen a significant push in recent years. The idea is that if employees better understand their health care options, they can save money and improve their overall well-being.
Even limited health literacy can go a long way toward keeping health costs down in 2022. Arming employees with questions such as “How much will this cost?” and “Can I be treated in an equally effective but less costly way?” can help them take better control over their health choices and make wiser decisions. Further, employees should also be taught basic concepts such as when to visit an emergency room versus an urgent care, the difference between coinsurance and deductibles, and how to price shop for services.
Ultimately, the more educated employees are about health care topics, the more money they can potentially save. In other words, the education employers invest in now will pay for itself later through healthier employees and reduced health expenses.
3. Telemedicine Solutions
Telemedicine allows consumers to visit their doctor over the internet. Unsurprisingly, that made it extremely popular during the height of the COVID-19 pandemic.
And that popularity isn’t likely to go away in 2022. Rather, more businesses are likely to shift toward offering more telemedicine options. According to McKinsey and Company, only 11% of U.S. consumers utilized telemedicine in 2019, pre-pandemic. As of mid-2021, 46% of consumers were using telemedicine to replace the in-person health visits they had originally planned. Additionally, 76% of consumers said they were interested in using telemedicine going forward, according to a separate McKinsey and Company survey.
Employers who want to test out telemedicine capabilities can think about offering it in a limited capacity. For instance, an employee might see a doctor in person for an annual checkup, then follow up later with a virtual visit. If employees find this useful, employers can consider expanding their telemedicine offerings.
4. Staffing Needs – On-Boarding and Terminations
A minimum 75% of PPP loans must be spent on staffing costs. Companies that had previously furloughed or terminated employees find they need to hire employees back. This comes with additional paperwork and many employee questions, such as whether benefits wait periods start over.
Conversely, when businesses do need to furlough or terminate employees, the PEO is a great guide for compliance. The layoff process, COBRA, paperwork including givernement reporting are supported.
5. Prescription Drug Policy Revisions
Partnering with a PEO is much like gaining access to a full-service HR division, with a team of HR experts who are up-to-date with new and changing employment laws and able to identify ways to streamline your HR.
According to a report conducted by the National Association of Professional Employer Organizations (NAPEO), PEOs provide access to more HR services at a cost that is close to $450 lower per employee, compared to companies that manage their HR services in-house.
Studies show that businesses in a PEO arrangement grow 7-9 percent faster, have 10-14 percent lower turnover, and are 50 percent less likely to go out of business.
6. Affordable and Better Benefits
By joining a large group risk-pool a a PEO can help employers gain access to high quality employee benefits, such as health insurance options with stable and affordable rates. Due to costs, small businesses often find high-quality employee benefits out of reach. The savings on health insurance alone can pay for the PEO itself.
Summary
There are many approaches for controlling benefits spending, but not all will work for each organization. That’s why it’s important for employers to closely analyze their health plan data and assess where they spend the most. This will help inform strategy and allow employers to maximize their efforts.
Reach out to World Insurance Associates, LLC to discuss cost-saving strategies that will fit your unique workforce. If you’re interested in hearing more about the advantages of partnering with a PEO, we’d love to talk to you. Fill out the form below or email info@medicalsolutionscorp.com for a FREE Consultation Today!
The information provided on this website is intended for informational purposes only. Millennium Medical Solutions Corp. does not offer legal or medical guidance. Those with legal or medical questions should seek appropriate assistance from a licensed professional. Stay up to date by signing up for Newsletter and Coronavirus Dashboard below.
Free At-Home COVID-19 Test available via USPS. On Jan. 18, every home in the United States can order up to four free COVID-19 tests. January 19, Americans will be able to order free at-home rapid COVID tests from the government at COVIDTests.gov.
The federal guidance requires commercial insurers and group health plans (both fully insured and self-insured) to reimburse consumers for the cost of Over-the-Counter (OTC) COVID-19 diagnostic tests, with or without an order or clinical assessment by a healthcare provider.
Types of COVID Tests:
Antigen tests, which test for an active infection by detecting specific virus proteins. Most at-home tests and “rapid tests” performed by healthcare providers fall in this category.
Molecular tests, which test for an active infection by amplifying genetic material from the virus. These are considered the “gold standard” for diagnosing COVID, as they are generally more accurate than antigen tests. The most familiar test from this category is the polymerase chain reaction (or PCR) test, which requires lab processing.
Antibody tests, which are blood tests that determine if the body has had an immune response to the virus. These tests are not used for diagnosing an active infection.
How Will this work with your Insurer?
Consistent with the guidance Insurers will utilize existing member claims submission procedures to provide benefits without cost-share for OTC COVID-19 tests that members purchase, either online or through other retailers. In addition to the member demographic information that is normally filed with member-submitted claims, the members will be required to certify that the test was purchased for personal use and not for employment purposes.
Customers may receive reimbursement for up to 8 COVID-19 OTC tests per covered individual per calendar month without a health care provider prescription or individualized clinical assessment. For a family of four covered individuals, that equates to 32 tests per month.
Members with Empire Blue Cross, for example, will utilize A.I. apps such as Sydney App or online. Separately, Insurers such as UnitedHealthcare will initially offer for at-home COVID-19 tests are Walmart Pharmacy and Rite Aid Pharmacy. When using Walmart or Rite-Aid there will be no up-front cost and you will not have to submit a form for reimbursement. Note, you may be required to go to the pharmacy counter to obtain the test kits at no cost.
If you’re interested in hearing more about the advantages of partnering with a PEO, we’d love to talk to you. Fill out the form below or email info@medicalsolutionscorp.com for a FREE Consultation Today!
The information provided on this website is intended for informational purposes only. Millennium Medical Solutions Corp. does not offer legal or medical guidance. Those with legal or medical questions should seek appropriate assistance from a licensed professional. Stay up to date by signing up for Newsletter and Coronavirus Dashboard below.
On December 2, 2021, the Biden administration issued a nine-pronged plan to combat COVID-19 as the winter months approach and the new Omicron variant poses risk of new infections. The plan covers:
1. Boosters for adults
2. Vaccinations to protect children and keep schools open
3. Expanded free at-home testing
4. International travel protections
5. Workplace protections
6. Rapid response teams to battle rising cases
7. Supplying treatment pills to help prevent
hospitalizations and death
8. Continued commitment to global vaccination efforts
9. Steps to ensure preparation for all scenarios
Aspects of this plan will affect employers and group health plans, as follows:
Expanded free at-home testing. The Departments of Labor, Health and Human Services, and the Treasury (collectively, the “Departments”) are directed to issue guidance by January 15, 2022, to clarify that individuals who purchase over-the-counter (“OTC”) COVID-19 diagnostic tests can seek reimbursement from their group health plan or health insurance issuer to cover the cost of the OTC test during the public health emergency.
The plan notes that consistent with current guidance, group health plans are not required to cover testing for public health surveillance or employment purposes.
PTO for booster shots. While all federal employees currently receive paid time off to get booster shots, employers are called upon to provide the same paid time off for their employees, if they are not doing so already, including paid time off for family members getting their first, second, or booster shots.
Targeting outreach to Medicare beneficiaries. CMS is launching an initiative to get Medicare beneficiaries booster shots. CMS will be sending all Medicare beneficiaries a notice providing information on access to booster shots in their community as well as emails.
• Protecting Workplaces to Keep Businesses Open. The administration is calling on businesses to move forward with requiring their workers to get vaccinated or be tested weekly. No new guidelines or requirements are part of this provision. The emphasis on encouragement is likely in response to the ongoing legal challenges to the federal vaccine mandates.
Currently, the courts have issued an enforcement stay with respect to the OSHA Emergency Temporary Standard (“ETS”), applicable to private employers, and a nationwide preliminary injunction with respect to both the CMS interim final rule applicable to health care workers and the federal contractor mandate.
Future guidance is expected to clarify and implement the provisions outlined in this plan. We are monitoring this information and will report on developments.
For information about transparency providers and new tech tools contact us at info@medicalsolutionscorp.com or (855)667-4621.
You can get ahead of cold and flu season by embracing a few habits that can help support a healthy immune system.
Plus, boosting your natural immunity doesn’t have to be time-consuming or expensive.
You may be doing some of these things already. If not, take baby steps to build new habits, because trying to do too much too soon may lead to frustration.
What steps can you take to fit these five tips into your life?
1. Get a good night’s rest.
Like stress, sleep deprivation can reduce the effectiveness of your immune system and lead to a longer recovery time if you do get sick.
Practice good sleep habits like putting away your devices before bed and creating a wind-down routine to help you relax.
2. Watch your stress levels.
Stress can weaken your immune system, making it harder to fight off a cold or the flu. Try practicing stress-reduction techniques such as daily meditation or breathing exercises.
3. Keep your hands clean.
Wash your hands often, especially when entering or leaving public places or touching surfaces. Cleaning your hands with soap and water for at least 20 seconds can be the best way to remove germs. When that’s not possible, use a hand sanitizer with at least 60% alcohol.
4. Stay active.
Exercise can help alleviate stress and support your immune system — and physical activity doesn’t have to be intense to make a difference. To get started, you can try taking a daily walk or practicing gentle yoga poses.
5. Focus more on nutrition.
A healthy diet supports a healthy immune system. In addition to the supplements, you may already take, try to eat foods rich in vitamins and minerals, such as:
Citrus fruits
Spinach
Green tea
Shellfish
Cleveland Clinic: We’re now several months into the coronavirus pandemic, and we’re also fast-approaching peak season for yet another viral illness: influenza. Infectious disease specialist Kristin Englund, MD, explains the differences between COVID-19 and the flu, and shares steps we can all take to help us stay healthy this flu season.
For information about transparency providers and new tech tools contact us at info@medicalsolutionscorp.com or (855)667-4621.
CMS and OSHA released interim final rules this week detailing the implementation of national vaccine requirements established by President Biden’s executive order in September.Yesterday, the Department of Labor released an unpublished version of the OSHA Emergency Temporary Standard (ETS).
The ETS is effective immediately and will cover 2/3rds of private employers. The OSHA ETS puts into effect the Biden Executive Order mandating all private employers with 100 or more employees ensure their employees are vaccinated against COVID-19, or submit negative weekly tests.
KEY Summary:
Covered Employers
Private employers with 100 or more employees enterprise-wide (across US locations) at the time these rules become effective
Independent contractors not included
Special franchisee, construction and staffing agency rules
Companies who grow will move into the covered group
State/local governments, including schools
Only state/local ordinances/laws that are not conflicting will have effect (i.e., if the state law prohibits vaccine mandates, OSHA ETS will supersede state law. OSHA ETS will be mandated.)
States with state OSHA plans may adopt these federal rules or similar rules. Some states are threatened with removal of state plan authority for failure to comply with laws as stringent as federal (e.g., UT & AZ)
Compliance Deadline
Within 30 days of publication (December 5)
Testing requirements within 60 days (January 4)
Mandate
Determine vaccination status of each employee
Obtain acceptable proof –
Maintain records/roster
Unvaccinated must test negative weekly if worker in workplace at least once a week or within 7 days before returning to work if worker is away from workplace a week or longer
Must wear face covering indoors or in occupied vehicle for work
Employer not required to pay for testing unless required by law or collective bargaining agreement
Employer not required to pay for face coverings
Notice
Employee must promptly notify of positive COVID test or receive diagnosis
Employer must remove employee from workplace, regardless of vaccination status
May not return to work until meeting criteria
Must provide paid time off for vaccination and recovery from side effects
In conclusion, employers subject to the ETS must determine whether they will take a vaccine-only or combined vaccine and testing/face covering approach to compliance and must develop the required written policies and communicate those policies to employees so they have ample time to receive their COVID-19 vaccines. Employers should work with legal counsel to develop their written policies and to address any reasonable accommodation requests received by employees.
If needing employment law assistance in implementing these new rules, contact your World Insurance Associates representative so that they can connect you a Jackson Lewis P.C. council in order to receive the WIA arrangement. For our PEO clients, please speak with in-house council and HR.
The information provided in this alert is not, is not intended to be, and shall not be construed to be, either the provision of legal advice or an offer to provide legal services, nor does it necessarily reflect the opinions of the agency, our lawyers, or our clients. This is not legal advice. Rather, the content is intended as a general overview of the subject matter covered.
Good news Bronx/Westchester. Oxford and Montefiore Health System announced moments ago that they have reached an agreement effective December 1, 2021 for UnitedHealthcare and Oxford employer-sponsored plans, as well as UnitedHealthcare’s Medicare Dual Special Needs Plan.
This resolves a split since Jan 1, 2021 which affected a significant percentage of local residents as both companies have a critical size of the market. Westchester and Bronx populations total nearly 2.5 million people. While this contract is resolved with titanic and a few Hospital Systems and Insurers left in the market we expect to see this trend to continue.
See below the official press release.
UnitedHealthcare and Montefiore Health System Renew Relationship
UnitedHealthcare and Montefiore Health System have reached a multi-year agreement that restores access to Montefiore’s hospitals and physicians for people enrolled in UnitedHealthcare and Oxford employer-sponsored plans as well as UnitedHealthcare’s Medicare Dual Special Needs Plan, effective Dec. 1, 2021.
We recognize that the care Montefiore provides is not only important but also personal to our members and we also know the negotiations process may have been difficult for them. Our top priority throughout this process was ensuring the people and employers we’re honored to serve in New York have access to quality, more affordable health care, and this new agreement helps accomplish that goal.
We thank our members and customers for their support and patience throughout this process. We are honored to continue supporting the more than 3.7 million individuals across New York who depend on us for access to quality and affordable health care.
Montefiore Hospitals & Health System
Facility Name
County
Montefiore Hospital (Moses Campus)
Bronx
Children’s Hospital at Montefiore
Bronx
Garnet Health MedJack D. Weiler Hospital (Einstein Campus)ical Center
Bronx
Montefiore Wakefield Hospital (Wakefield Campus)
Bronx
Burke Rehabilitation Hospital
Westchester
Montefiore Mount Vernon Hospital
Westchester
Montefiore New Rochelle Hospital
Westchester
Montefiore Nyack Hospital
Rockland
Montefiore St Luke’s Cornwall Hospital
Orange
White Plains Hospital
Bronx
Montefiore Hutchinson Campus
Bronx
Montefiore Medical Group
Westchester
Montefiore Medical Specialists of Westchester
Westchester
Neighboring Hospitals
Facility Name
County
Bon Secours Community Hospital BronxCare Hospital Center Garnet Health Medical Center Good Samaritan Hospital of Suffern New York Presbyterian Hudson Valley Hospital New York Presbyterian Lawrence Hospital NYC Health + Hospitals Jacobi NYC Health + Hospitals Lincoln NYC Health + Hospitals North Central Bronx St. Anthony Community Hospital St. Barnabas Hospital St. John’s Riverside Hospital Westchester Medical Center
Medicare Supplemental Plan F phased out for newly Medicare eligible? With the new 2022 open enrollment changes, it’s time to get the facts. Considering making changes to your coverage this fall or just want to learn more about this enrollment period?
During the Medicare open enrollment period – which runs from October 15 through December 7 – you can make a variety of changes (none of which involve medical underwriting):
Switch from Medicare Advantage toOriginal Medicareor vice versa.
Switch from one Medicare Advantage plan to another.
Switch from onePart D prescription planto another.
Join a Medicare Part D plan.
Drop your Part D coverage altogether.
1. Medicare Supplement Plans F and C are still available
While the Centers for Medicare and Medicaid (CMS) will no longer allow newly eligible Medicare beneficiaries to enroll in Medigap plans F and C, these plans aren’t disappearing completely. If you become eligible for Medicare before January 1, 2021 (and that’s everyone who can use the 2021 fall Medicare Open Enrollment Period), you can apply for these plans now and in the future—even if you aren’t already enrolled in Medigap.
If you become eligible for Medicare on or after January 1, 2020, you won’t be able to enroll in Plans F or C now or in the future.
2. The Part D ‘donut hole’ will close
In 2022, you’ll enter the donut hole when your spending + your plan’s spending reaches $4,430. And you leave the donut hole — and enter the catastrophic coverage level — when your spending + manufacturer discounts reach $7,050. Both of these amounts are higher than they were in 2021, and generally increase each year. Learn more about Part D.
3. Changes in Medicare Advantage and Part D plans
Every year, insurers make small changes to their Medicare Advantage and Part D plans. Typically, these changes include changes in premiums, deductibles, and other costs. Keep in mind, the Medicare program may not finalize these changes until right before fall Open Enrollment.
See the latest Medicare premiums and deductibles now or come back in October. We’ll share finalized changes as soon as they become available.
Refresh your general Medicare knowledge
While the Medicare program changes a bit each year, much of it stays the same. It never hurts to refresh your Medicare knowledge. We recommend starting with an Overview of Medicare. This Medicare Glossary could come in handy, too, as you read through insurance documents. See
Medicare Part B premiums increased this year by about 2.7% or $4 per month and high-income surcharges also rose modestly in 2021. For 2022 the Standard Part B premiums are projected to be $158.50/month from $148.50/month in 2021 or a 6.7% increase.
The wealthiest senior couples will be paying more than $12,000 a year in Medicare Part B premiums. Part B (the base and the surcharge) covers doctors’ and outpatient services. Medicare Part B Income-Related Monthly Adjustment Amounts.
5. Part B deductible also increased for 2021, and will increase again in 2022
Medicare B also has a deductible, which increased to$203 in 2021, up from$198 in 2020. For 2022, the Part B deductible isprojected to be $217. The Medicare Part B deductible only has to be paid once per year, unlike the Part A deductible, which has to be paid once perbenefit period.
Do you have to renew your plan?
If you’re happy with your Medicare coverage, there’s no need to do anything during Medicare Open Enrollment. Provided your current plan is available next year, your coverage will auto-renew.
Although you could let Open Enrollment pass right on by without having to lift a finger, we recommend doing two things this fall to optimize your Medicare coverage.
1. Read Medicare Mailers
If your plan is discontinued next year, you’ll receive a notice in the mail. If you miss this notice and fail to enroll in other coverage, you could lose your coverage.
If your plan continues in the following year, your insurer will send you an Annual Notice of Change (ANOC). Look over your ANOC carefully to make sure your plan will still meet your needs next year. If not, its time to consider other options.
No matter how you feel about your current plan, it’s usually a good idea to do a little shopping around during Open Enrollment. Since plans and premiums change annually, options that fit your situation even better than your current coverage could pop up. But if you don’t check, you’ll never know.
Know These Dates
OCT 15 - DEC 7
OPEN ENROLLMENT PERIOD for Medicare Advanatage and Medicare Part D Prescription Drug coverage. All individuals with Medicare can change their Medicare health plan and prescription drug coevrage for the next year.
JAN 1 - FEB 14
MEDICARE ADVANTAGE DISENROLLMENT PERIOD. Those with MA plans (Part C) can leave the plan and switch to original Medicare.
JAN 1 - DEC 31
MEDICARE SUPPLEMENT (Medigap) plans can be purchaded year-round but may require answering health questions to determine eligibility.
Total Number of Million Medicare Beneficiaries. Source: Kaiser Family Foundation
2020
2018
2017
2015
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Cybersecurity Awareness Month is intended to raise employee awareness in every way possible.
It’s never been more important for cybersecurity to be top of mind for all of us. We are all connected to the internet both professionally and personally, therefore, we are all exposed to the bad guys. To that end, it’s important that we know how to prevent cybersecurity attacks and what it means to do our part and be Cyber Smart.
Stats
The U.S government allocated an estimated $18.78 billion for cybersecurity spending in 2021.
Damage related to cybercrime is projected to hit $10.5 trillion annually by 2025.
64% of Americans have never checked to see if they were personally affected by a data breach.
16% of healthcare providers reporting having “fully functional” security programs.
In April 2020, Google blocked 18 million daily malware and phishing emails related to COVID.
89% of healthcare organizations had patient data lost or stolen in the past two years.
Google has registered 2,145,013 phishing sites as of January 17, 2021. This is up from 1,690,000 on January 19, 2020.
20% of organizations said they faced a security breach as a result of a remote worker.
Norton LifeLock Advantage
We are excited to announce a new partnership with NortonLifeLock for SMB with two or more employees, provide a cybersecurity offering to their employees. As a global leader in consumer cyber safety, NortonLifeLock has built a comprehensive and easy-to-use integrated portfolio that prevents, detects, and responds to cyber threats and cybercriminals in today’s digital world. With over four decades of experience in cybersecurity and identity theft protection, NortonLifeLock helps people live their digital lives safely and has earned the trust of over 80 million users in more than 150 countries. Learn more in this shortvideo.
Everyday actions including online shopping, banking, and even simply browsing the internet can expose your clients’ personal information and make them more vulnerable to cybercriminals. Since cybercrime hasevolved, NortonLifeLock has evolved as well. LifeLock, a leader in identity theft protection, and Norton, a pioneer in consumer cybersecurity, are now one company. Their innovative employee benefit plans will helpprotect an employee’s identity, personal information, and connected devices against the myriad of threats they may face in their digitally connected homes, workplaces, and when using public Wi-Fi.
If you see something say something. The bad guys only have to get it right once, we need to get it right every time!
Our WIA Cyber Team and helpdesk are here to help our clients. . Take a company audit, your preparedness is your responsibility.
A little-known requirement but most important under Affordable Care Act (ACA) is for Health Insurers must waive their minimum employer-contribution and employee-participation rules once a year. ACA requires a one-month Special Open Enrollment Window for January 1st coverage.
The special open enrollment period occurs November 15th through December 15th of each year, allowing eligible small group employers to enroll for coverage effective January 1st of the following year.
Background
The ACA has a section in it called the “guaranteed issuance of coverage in the individual and group market.” It stipulates that “each health insurer that offers health insurance coverage in the individual or group market in the state must accept every employer and individual in the state that applies for such coverage.” The section also states that this guaranteed issuance of coverage can only be offered during (special) open enrollment periods, and that plans can only be offered to applicants that live in, work in, or reside in the plans’ service area(s).
Participation and Contribution Requirements
In many states (including California and Nevada), carriers can decline to issue group health coverage if fewer than 70% of employees elect to enroll in coverage. Some carriers may have even tighter participation requirements.
Generally speaking, employees with other coverage (Medicare, other group coverage, individual coverage through the Exchange, etc.) are removed from the participation requirement calculation – though it varies by insurance carrier.
Furthermore, employer contribution rules require employers to contribute a certain percentage of premium costs for all employees in order to attain group health coverage. Some businesses struggle to meet these contribution requirements for a variety of financial reasons.
Problem Solved: Special Open Enrollment Period
Many employers want to offer coverage to their employees, but are denied because they struggle to meet participation and/or contribution requirements. Employers cannot force employees to enroll in coverage unless the employer pays for 100% of the employees’ premiums, which many employers cannot afford. Even with moderate to generous employer contributions, many employers still find young and lower-income employees waiving coverage. This was even more evident in 2019 with the ACA’s federal Individual Mandate non-compliance penalty reduced to $0.00.
The U.S. Department of Health & Human Services provides final guidance on this in regulation 147.104(b)(1): “In the case of health insurance coverage offered in the small group market, a health insurance issuer may limit the availability of coverage to an annual enrollment period that begins November 15 and extends through December 15 of each year in the case of a plan sponsor that is unable to comply with a material plan provision relating to employer contribution or group participation rules.”
If your employer groups are struggling with participation and/or contribution, the Special Open Enrollment Window is the time to enroll them in coverage.
This Compliance Overview is not intended to be exhaustive nor should any discussion or opinions be construed as legal advice. Readers should contact legal counsel for legal advice.
In preparation for open enrollment, Employers should review their plan documents in light of changes for the plan year beginning Jan 1, 2021. Below is an Employer 2 Open Enrollment Checklist including some administrative items to prepare for in 2020.
Health plan sponsors should also confirm that their open enrollment materials contain certain required participant notices, when applicable—for example, the summary of benefits and coverage (SBC). There are also some participant notices that must be provided annually or upon initial enrollment. To minimize costs and streamline administration, employers should consider including these notices in their open enrollment materials.
PLAN DESIGN CHANGES
Out-of-pocket Maximum
Effective for plan years beginning on or after Jan. 1, 2014, non-grandfathered health plans are subject to limits on cost-sharing for essential health benefits (EHB). The ACA’s out-of-pocket maximum applies to all non-grandfathered group health plans, including self-insured health plans and insured plans.
$8,700 for self-only coverage and $17,400 for family coverage out-of-pocket maximum.
$7,050 for self-only coverage and $14,100 for family coverage HSA Maximum. For 2021 plan years, the out-of-pocket maximum limit for HDHPs is $7,000 for self-only coverage and $14,000 for family coverage.
Preventive Care Benefits
The ACA requires non-grandfathered health plans to cover certain preventive health services without imposing cost-sharing requirements (that is, deductibles, copayments or coinsurance) for the services. Health plans are required to adjust their first-dollar coverage of preventive care services based on the latest preventive care recommendations. If you have a non-grandfathered plan, you should confirm that your plan covers the latest recommended preventive care services without imposing any cost-sharing.
The ACA imposes a dollar limit on employees’ salary reduction contributions to a health flexible spending account (FSA) offered under a cafeteria plan. An employer may impose its own dollar limit on employees’ salary reduction contributions to a health FSA, as long as the employer’s limit does not exceed the ACA’s maximum limit in effect for the plan year.
The ACA set the health FSA contribution limit at $2,500. For years after 2013, the dollar limit is indexed for cost-of-living adjustments. For 2022 plan years, the health FSA limit is $2,850. The DFSA Rollover Maximum is $570.
Communicate the health FSA limit to employees as part of the open enrollment process.
HDHP and HSA Limits for 2022
If you offer an HDHP to your employees that is compatible with an HSA, you should confirm that the HDHP’s minimum deductible and out-of-pocket maximum comply with the 2020 limits. The IRS limits for HSA contributions and HDHP cost-sharing increase for 2022. The HSA contribution limits will increase effective Jan. 1, 2022, while the HDHP limits will increase effective for plan years beginning on or after Jan. 1, 2022.
Check whether your HDHP’s cost-sharing limits need to be adjusted for the 2022 limits.
If you communicate the HSA contribution limits to employees as part of the enrollment process, these enrollment materials should be updated to reflect the increased limits that apply for 2022.
The following table contains the HDHP and HSA limits for 2022 as compared to 2021. It also includes the catch-up contribution limit that applies to HSA-eligible individuals who are age 55 or older, which is not adjusted for inflation and stays the same from year to year.
Type of Limit
2021
2022
Change
HSA Contribution Limit
Self-only
$3,600
$3,650
Up $50
Family
$7,200
$7,300
Up $100
HSA Catch-up Contributions (not subject to adjustment for inflation)
Age 55 or older
$1,000
$1,000
No change
HDHP Minimum Deductible
Self-only
$1,400
$1,400
No change
Family
$2,800
$2,800
No change
HDHP Maximum Out-of-pocket Expense Limit (deductibles, copayments and other amounts, but not premiums)
Self-only
$7,000
$7,050
Up $50
Family
$14,000
$14,100
Up $100
ACA EMPLOYER MANDATE AND OTHER REQUIREMENTS
Applicable Large Employer Status (ALE)
Under the ACA’s employer penalty rules, applicable large employers (ALEs) that do not offer health coverage to their full-time employees (and dependent children) that is affordable and provides minimum value will be subject to penalties if any full-time employee receives a government subsidy for health coverage through an Exchange.
To qualify as an ALE, an employer must employ, on average, at least 50 full-time employees, including full-time equivalent employees (FTEs), on business days during the preceding calendar year. All employers that employ at least 50 full-time employees, including FTEs, are subject to the ACA’s pay or play rules.
Determine your ALE status for 2022
Calculate the number of full-time employees for all 12 calendar months of 2020. A full-time employee is an employee who is employed on average for at least 30 hours of service per week.
Calculate the number of FTEs for all 12 calendar months of 2021 by calculating the aggregate number of hours of service (but not more than 120 hours of service for any employee) for all employees who were not full-time employees for that month and dividing the total hours of service by 120.
Add the number of full-time employees and FTEs (including fractions) calculated above for all 12 calendar months of 2021.
Add up the monthly numbers from the preceding step and divide the sum by 12. Disregard fractions.
If your result is 50 or more, you are likely an ALE for 2022.
Identify Full-time Employees
All full-time employees must be offered affordable minimum value coverage. A full-time employee is an employee who was employed on average at least 30 hours of service per week. The final regulations generally treat 130 hours of service in a calendar month as the monthly equivalent of 30 hours of service per week. The IRS has provided two methods for determining full-time employee status—the monthly measurement method and the look-back measurement method.
Determine which method you are going to use to determine full-time status
The monthly measurement method involves a month-to-month analysis where full-time employees are identified based on their hours of service for each month. This method is not based on averaging hours of service over a prior measurement method. Month-to-month measuring may cause practical difficulties for employers, particularly if there are employees with varying hours or employment schedules, and could result in employees moving in and out of employer coverage on a monthly
The look-back measurement method allows an employer to determine full-time status based on average hours worked by an employee in a prior period. This method involves a measurement period for counting/averaging hours of service, an administrative period that allows time for enrollment and disenrollment, and a stability period when coverage may need to be provided, depending on an employee’s average hours of service during the measurement
Audit FTEs for FMLA Compliance
Audit your FTEs to determine if you have reached or exceeded 50 employees and are required to comply with the Family Medical Leave Act (FMLA) in 2022. Employers covered by the FMLA are obligated to provide their employees with certain important FMLA notices, so both employees and the employer have a shared understanding of the terms of the FMLA leave. Note that FMLA compliance requirements are different from ACA compliance.
Offer of Coverage
An ALE may be liable for a penalty under the pay or play rules if it does not offer coverage to “substantially all” (95%) full-time employees (and dependents) and any one of its full-time employees receives a premium tax credit or cost-sharing reduction for coverage purchased through an Exchange. For employees who are offered health coverage that is affordable and provides minimum value are generally not eligible for these Exchange subsidies. The IRS lowered the 2022 employer health plan affordability threshold, or cost-sharing limit, to 9.61% of an employee’s income. The threshold in 2021 was 9.83%.
Offer minimum essential coverage to all full-time employees
Ensure that at least one of those plans provides minimum value (60% actuarial value)
Ensure that the minimum value plan offered is affordable to all full-time employees by ensuring that the employee contribution for the lowest cost single minimum value plan does not exceed 78% of an employee’s earnings based on the employee’s W-2 wages, the employee’s rate of pay, or the federal poverty level for a single individual.
Reporting of Coverage
The ACA requires ALEs to report information to the IRS and to employees regarding the employer-sponsored health coverage on Form 1095-C. The IRS will use the information that ALEs report to verify employer-sponsored coverage and to administer the employer shared responsibility provisions (Code Section 6056).
In addition, the ACA requires every health insurance issuer, sponsor of a self-insured health plan, a government agency that administers government-sponsored health insurance programs and any other entity that provides minimum essential coverage (MEC) to file an annual return with the IRS and individuals reporting information for each individual who is provided with this coverage (Code Section 6055).
Determine which reporting requirements apply to you and your health plans
Determine the information you will need for reporting and coordinate internal and external resources to help compile the required data for the 1094-C and 1095-C
Complete the appropriate forms for the 2020 reporting year. Furnish statements to individuals on or before January 31, 2021 has been extended to March 2, 2021 IRS Notice 2020-76., and file returns with the IRS on or before February 28, 2020 (March 31, 2020, if filing electronically).
ACA Requirement
Deadline
1095 forms delivered to employees
Jan. 31 (extended to March 2)
Paper filing with IRS*
Feb. 28
Electronic filing with IRS
March 31
Comparative Effectiveness Research Fee (PCORI)
Sponsors of self-funded plans and health insurance issuers of fully insured plans are required to pay a fee each year, by July 31st, to fund comparative effectiveness research. Fees will increase to $2.45 per covered life in 2020 and are next due July 31, 2021.
W-2 Reporting
Healthcare Reform requires employers to report the aggregate cost of employer-sponsored group health plan coverage on their employees’ Forms W-2. This reporting requirement was originally effective for the 2011 tax year. However, the IRS later made reporting optional for 2011 for all employers.
The IRS further delayed the reporting requirement for small employers (those that file fewer than 250 Forms W-2) by making it optional for these employers until further guidance is issued. For the larger employers, the reporting requirement was mandatory for the 2012 Forms W-2 and continues.
ACA DISCLOSURE REQUIREMENTS
Summary of Benefits and Coverage
The ACA requires health plans and health insurance issuers to provide an SBC to applicants and enrollees to help them understand their coverage and make coverage decisions. Plans and issuers must provide the SBC to participants and beneficiaries who enroll or re-enroll during an open enrollment period. The SBC also must be provided to participants and beneficiaries who enroll other than through an open enrollment period (including those who are newly eligible for coverage and special enrollees).
In connection with a plan’s 2020 open enrollment period, the SBC should be included with the plan’s application materials. If coverage automatically renews for current participants, the SBC must generally be provided no later than 30 days before the beginning of the new plan year.
For self-funded plans, the plan administrator is responsible for providing the SBC. For insured plans, both the plan and the issuer are obligated to provide the SBC, although this obligation is satisfied for both parties if either one provides the SBC. Thus, if you have an insured plan, you should confirm that your health insurance issuer will assume responsibility for providing the SBCs.
Grandfathered Plan Notice
If you have a grandfathered plan, make sure to include information about the plan’s grandfathered status in plan materials describing the coverage under the plan, such as SPDs and open enrollment materials. Model language is available from the DOL.
Notice of Patient Protections
Under the ACA, non-grandfathered group health plans and issuers that require designation of a participating primary care provider must permit each participant, beneficiary and enrollee to designate any available participating primary care provider (including a pediatrician for children). Also, plans and issuers that provide obstetrical/gynecological care and require a designation of a participating primary care provider may not require preauthorization or referral for obstetrical/gynecological care.
If a non-grandfathered plan requires participants to designate a participating primary care provider, the plan or issuer must provide a notice of these patient protections whenever the SPD or similar description of benefits is provided to a participant. If your plan is subject to this notice requirement, you should confirm that it is included in the plan’s open enrollment materials. Model language is available from the DOL.
OTHER NOTICES
Group health plan sponsors should consider including the following enrollment and annual notices with the plan’s open enrollment materials.
Initial COBRA Notice
The Consolidated Omnibus Budget Reconciliation Act (COBRA) applies to employers with 20 or more employees that sponsor group health plans. Plan administrators must provide an initial COBRA notice to new participants and certain dependents within 90 days after plan coverage begins. The initial COBRA notice may be incorporated into the plan’s SPD. A model initial COBRA notice is available from the DOL.
Notice of HIPAA Special Enrollment Rights
At or prior to the time of enrollment, a group health plan must provide each eligible employee with a notice of his or her special enrollment rights under HIPAA. This notice may be included in the plan’s SPD. Model language for this disclosure is available on the DOL’s website.
Annual CHIPRA Notice
Group health plans covering residents in a state that provides a premium subsidy to low-income children and their families to help pay for employer-sponsored coverage must send an annual notice about the available assistance to all employees residing in that state. The DOL has provided a model notice.
WHCRA Notice
Plans and issuers must provide notice of participants’ rights to mastectomy-related benefits under the Women’s Health and Cancer Rights Act (WHCRA) at the time of enrollment and on an annual basis. Model language for this disclosure is available on the DOL’s website.
NMHPA Notice
Plan administrators must include a statement within the Summary Plan Description (SPD) timeframe describing requirements relating to any hospital length of stay in connection with childbirth for a mother or newborn child under the Newborns’ and Mothers’ Health Protections Act. Model language for this disclosure is available on the DOL’s website.
Medicare Part D Notices
Group health plan sponsors must provide a notice of creditable or non-creditable prescription drug coverage to Medicare Part D eligible individuals who are covered by, or who apply for, prescription drug coverage under the health plan. This creditable coverage notice alerts the individuals as to whether or not their prescription drug coverage is at least as good as the Medicare Part D coverage. The notice generally must be provided at various times, including when an individual enrolls in the plan and each year before Oct. 15th(when the Medicare annual open enrollment period begins). Model notices are available on the Centers for Medicare and Medicaid Services’ website.
HIPAA Privacy Notice
The HIPAA Privacy Rule requires covered entities (including group health plans and issuers) to provide a Notice of Privacy Practices (or Privacy Notice) to each individual who is the subject of protected health information (PHI). Health plans are required to send the Privacy Notice at certain times, including to new enrollees at the time of enrollment. Also, at least once every three years, health plans must either redistribute the Privacy Notice or notify participants that the Privacy Notice is available and explain how to obtain a copy.
Self-insured health plans are required to maintain and provide their own Privacy Notices. Special rules, however, apply for fully insured plans. Under these rules, the health insurance issuer, and not the health plan itself, is primarily responsible for the Privacy Notice.
Model Privacy Notices are available through the Department of Health and Human Services
Summary Plan Description (SPD)
Plan administrators must provide an SPD to new participants within 90 days after plan coverage begins. Any changes that are made to the plan should be reflected in an updated SPD booklet or described to participants through a summary of material modifications (SMM).
Also, an updated SPD must be furnished every five years if changes are made to SPD information or the plan is amended. Otherwise, a new SPD must be provided every 10 years.
Summary Annual Report
Plan administrators that are required to file a Form 5500 (> 100 participants in plan) must provide participants with a narrative summary of the information in the Form 5500, called a summary annual report (SAR). The plan administrator generally must provide the SAR within nine months of the close of the plan year. If an extension of time to file the Form 5500 is obtained, the plan administrator must furnish the SAR within two months after the close of the extension period.
Wellness Program Notices
Group health plans that include wellness programs may be required to provide certain notices regarding the program’s design. As a general rule, these notices should be provided when the wellness program is communicated to employees and before employees provide any health-related information or undergo medical examinations.
HIPAA Wellness Program Notice—HIPAA imposes a notice requirement on health-contingent wellness programs that are offered under group health plans. Health-contingent wellness plans require individuals to satisfy standards related to health factors (for example, not smoking) in order to obtain rewards. The notice must disclose the availability of a reasonable alternative standard to qualify for the reward (and, if applicable, the possibility of waiver of the otherwise applicable standard) in all plan materials describing the terms of a health-contingent wellness program. Final regulations provide sample language that can be used to satisfy this requirement.
ADA Wellness Program Notice—Employers with 15 or more employees are subject to the Americans with Disabilities Act (ADA). Wellness programs that include health-related questions or medical examinations must comply with the ADA’s requirements, including an employee notice requirement. Employers must give participating employees a notice that tells them what information will be collected as part of the wellness program, with whom it will be shared and for what purpose, the limits on disclosure and the way information will be kept confidential. The Equal Employment Opportunity Commission (EEOC) has provided a sample notice to help employers comply with this ADA requirement.
Enhance Your Employee Benefits Package. A competitive benefits package is key to keeping and attracting top talent.Assess your current benefits package and consider making necessary adjustments to include options, such as expanded mental health support, for example.
GENERAL HR
Review Employee Records. The fourth quarter is a good time to review your employee records and check record retention guidelines. Don’t forget to dispose of outdated termination and outdated job applications properly. With W2s around the corner, make sure all addresses and information are updated.
Develop and Distribute Your 2022 Calendar. Create and distribute a calendar outlining important dates, vacation time, pay dates, and company-observed holidays for 2022.
Review and Update Employee Handbook. Review your employee handbook to make sure it is up-to-date and addresses areas, such as employment law mandates, new COVID-related policies, guidelines for remote working, privacy policies, compensation and performance reviews, social media policies, attendance, and time-off, break periods, benefits, and procedures for termination, discipline, workplace safety, and emergency procedures.
PLEASE NOTE: This information is for general reference purposes only. Because laws, regulations, and filing deadlines are likely to change, please check with the appropriate organizations or government agencies for the latest information and consult your employment attorney and/or benefits advisor regarding your responsibilities. In addition, your business may be exempt from certain requirements and/or be subject to different requirements under the laws of your state. (Updated Oct. 3, 2021)
Contact us at (855) 667-4621 or email us at info@medicalsolutionscorp.com