It’s Time to Plan ACA Reinsurance Payments

By Michael Berwanger, JD, Director, Quality Management & Compliance

 

shutterstock_68891791It is time for employer-sponsored health plans to begin thinking about the process for calculation and submission of enrollment data and payment of fees under the Transitional Reinsurance Program.

As background, this program was established to fund a reinsurance pool to help stabilize premiums in the insurance markets created under the Affordable Care Act (ACA).

The program is being funded by three annual assessments on employer-sponsored health plans. The assessments are for average covered lives in 2014, 2015 and 2016 calendar years.

This year, enrollment data must be submitted by November 15, 2016, and payment must be submitted no later than January 17, 2017.

The 2016 Reinsurance Contribution Rate is $27.00 per covered life.

Online Submission Process

The Centers for Medicare and Medicaid Services (CMS) has implemented a streamlined process for reinsurancethe collection of reinsurance contributions. A contributing entity, or a Third Party Administrator (TPA) on its behalf, can complete all required steps for the reinsurance contributions process online (using the government portal, pay.gov), including registration, submission of annual enrollment count, and remittance of contributions.

A form is available for the contributing entity (or its TPA) to provide basic company and contact information and the annual enrollment count for the applicable year. The form will automatically calculate the contribution amounts, and entities will be required to submit payment information and schedule a payment date for remittance of the contributions.

CMS will not send an invoice to contributing entities. All required action will be completed online at pay.gov.

Options for Payment

There are two options for how a contributing entity can make a payment: (1) a one-time lump sum payment, or (2) a full contribution in two payments. (See chart below.)

Contribution Payment Options for the 2016 Benefit Year

Reinsurance

Source: Centers for Medicare and Medicaid Services

CMS will permit contributing entities to submit each year’s contribution in two separate payments – one larger payment of $21.60 per covered life at the start of the year, and a smaller payment of $5.40 per covered life at the end of the year.

However, when submitting enrollment data, dates must immediately be scheduled for payment of the fees, whether there will be one payment prior to January 17, 2017, or two payments with the later in November 2017.

If You Are Self-funded for a Portion of the Reporting Period

health insurance noticesFor a plan that has moved from a fully insured plan to a self-funded plan during the first nine months of the 2016 calendar year, both plans will be responsible for paying a portion of the fee, using one of the permitted calculation methods.

Since fully-insured plans are not permitted to use the Snapshot Factor Method of calculation, either the Actual Count Method or the Snapshot Method of calculation must be used.

Helpful Resources

This site provides technical assistance and training related to the Marketplace and Premium Stabilization program (which includes the Transitional Reinsurance Program). Webinars are offered that provide entities with information on program and operational guidance, along with live demos of the enrollment count and contributions submission process.

This is the site where the contributing entity, or TPA, will create a profile, and submit the enrollment data and contributions for the Transitional Reinsurance Program.

This website is hosted by the Centers for Medicare and Medicaid to provide information about the Transitional Reinsurance Program.

For more information, consult your broker, legal advisor or cms.gov. MedCost

This blog post should not be considered as legal advice.

 

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Is Your Health Plan Affected by the Cadillac Tax?

One-Fourth of Employers Now Offering CDHPs to Avoid Tax

Employers continue to take action to avoid the looming excise or “Cadillac” tax on more expensive health insurance for their employees. This Affordable Care Act tax of 40% annually is currently set to take effect in 2020, but it is already having a major impact.

A 2015 Mercer study found that total health benefits cost averaged $11,635 per employee.[i] Cadillac taxThis average amount exceeds the Cadillac tax’s threshold of $10,200 for individuals, and would trigger the 40% tax on benefits above the threshold. And small employers are seeing higher increases in medical, dental and other health benefits than large employers.

Employers Turn to
Consumer Plans                                             

For the first time, 25% of covered employees are now enrolled in Consumer-Driven Health Plans (CDHP). Large employers of 20,000 or more employees have added CDHPs the fastest (73%). A projected 34% of employers with 50+ employees will be subject to the excise tax in 2020 if they make no changes to their current health plans.

 Cadillac tax

 

High-Deductible Health Plans (HDHP) are a type of Consumer-Driven Health Plans. Employers are saving an average of 18% with an HSA-eligible HDHP instead of a traditional Preferred Provider Organization (PPO) plan.[ii]

One key reason that employees are researching medical costs in advance for services such as maternity care, joint replacements and Emergency Room visits. A 2015 Consumer Health Insights’ survey showed that 22% always talked to others about costs or searched websites for information.[iii]

Employees who have a telemedicine option in their health plans can choose a more appropriate level of Cadillac taxcare for certain respiratory infections, fevers and nausea (see “Treatment Alternatives to the Emergency Room”). Choosing the right level of care reduces time away from work, boosting productivity. And employees save unnecessary dollars from their own pockets.

Some employers offer pricing transparency tools such as HealtheReports™ which compares costs for a complete procedure. Employees can review local facilities that offer mammograms, colonoscopies, X-rays and other services. HealtheReports also lists comments from members about their recommendations for health care organizations.

A New Era in Health Care

CDHP plans require a shift in thinking about medical spending. In traditional plans, employees are used to handing over their insurance card and paying a small copay.

PiggyBankIt can come as a jolt to employees to realize that CDHP coverage begins with paying expenses up to a higher deductible before insurance kicks in. For this reason, employers must proactively educate employees when introducing CDHP options.

Our next blog will detail key steps for employers to take in providing tools for smart decision-making. Employers who can manage staff expectations with a balanced understanding of the changing health care industry will build a productive partnership with your team.MedCost

 

[i] “With the Excise Tax in Their Sights, Employers Hold Health Benefits Cost Growth to 3.8% in 2015,” Mercer Global, November 19, 2015, http://www.mercer.com/newsroom/national-survey-of-employer-sponsored-health-plans-2015.html (accessed August 8, 2016)

[ii] Ibid.

[iii] “Debunking Common Myths about Healthcare Consumerism,” McKinsey & Company, December 2015, http://www.mckinsey.com/industries/healthcare-systems-and-services/our-insights/debunking-common-myths-about-healthcare-consumerism (accessed August 11, 2016)

HHS Nondiscrimination Rule: FAQs

By Michael Berwanger, JD, Director, Quality Management & Compliance

medicalOn May 18, 2016, the Department of Health and Human Services (HHS) published a final rule (the “Rule”) to implement Section 1557 of the Affordable Care Act (ACA), which prohibits discrimination in health coverage and care based on race, color, national origin, age, disability, and sex.

Notably, the Rule:

  • Extends protections against sex discrimination to health coverage and care for the first time, including gender identity discrimination within the definition of sex discrimination;
  •  Implements guidance regarding meaningful access for individuals with Limited English Proficiency, including the provision of free, accurate, and timely language assistance services;
  •  Incorporates existing law that requires reasonable modifications, effective communication, and readily accessible buildings and information technology to avoid disability-based discrimination; and
  •   Prohibits discriminatory health insurance benefit designs and includes specific coverage protections for transgender individuals.

ACA, health insurance, health exchangesHHS has published a useful FAQ here summarizing some of the key aspects of Section 1557. The following Q&A helps explain who the Rule applies to, how the Rule protects against discrimination, and how the Rule impacts coverage offered by self-funded health plans.

I. Who does the Rule apply to?

The Rule applies to (i) every health program or activity that receives Federal financial assistance from HHS; (ii) health programs administered by HHS, and (iii) federally-facilitated and state-based marketplaces established under the Affordable Care Act.

Some examples of types of entities that are subject to the Rule include but are not limited to: physician practices, hospitals, health clinics, health insurance programs, state Medicaid agencies, community health centers, home health care agencies, the Health Insurance Marketplaces, or employers offering employee health benefit programs (in certain circumstances).

How does this impact religious organizations?

The Rule does not include a blanket religious exemption related to Section 1557’s general prohibition against sex discrimination. However, HHS stated that “[e]xisting laws protecting religious freedom and belief, including provider conscience laws, the Religious Freedom Restoration Act, the ACA’s provisions regarding abortion services, and the ACA’s preventive health services regulations, continue to apply.”

It may be prudent to consult with your legal counsel if you think your organization may qualify for a religious exemption.

EEOC, employer wellness program, wellness program, ACA, GINA
II. When does this take effect for a health plan?

Provisions of the Rule that require changes in plan benefit design take effect in the first plan year on or after January 1, 2017.

III. What does the Rule prohibit?

Under Section 1557, covered entities may not take the following actions on the basis of race, color, national origin, sex, age or disability:

  • Deny, cancel, limit, or refuse to issue or renew a health insurance policy;
  • Deny or limit coverage of a health insurance claim;
  • Impose additional cost sharing or other limitations or restrictions on coverage; or
  • Use discriminatory marketing practices or insurance benefit designs.

The Rule maintains that while health plans cannot have coverage policies that operate in a discriminatory manner, they still may apply medical necessity rules when determining covered benefits.

HHS clarified that they do not affirmatively require covered entities to cover any particular treatment, as long as the basis for exclusion is evidence based and nondiscriminatory.

What about gender transition services? Are health plans required to cover those services?

If a company is a covered entity under the Rule, not subject to an exception such as the religious exemptions, and the gender transition service is determined to be medically necessary, then it is likely that the service must be covered by the plan. Note that HHS declined to specifically require a gender transition provision.

However, covered entity plans are prevented from discriminating in the provision of benefits based on employer benefit planssex. As such, services such as transition-related services may be subject to medical necessity requirements, but the process for determining medical necessity must also be nondiscriminatory.

For example, HHS stated “[t]he range of transition-related services, which includes treatment for gender dysphoria, is not limited to surgical treatments and may include, but is not limited to, services such as hormone therapy and psychotherapy, which may occur over the lifetime of the individual. We believe the flexibility of the general language in the final rule best serves transgender individuals and covered entities.”

Note that, as mentioned above, the Rule does not affirmatively require covered entities to cover any particular procedure or treatment for transition-related care. The Rule also does not preclude a covered entity from applying neutral standards that govern the circumstances in which it will offer coverage to all its enrollees in a nondiscriminatory manner.

IV. What changes happened regarding sex discrimination?

Section 1557 and HHS’s final regulations, for the first time, extend protections against discrimination based on sex to health coverage and care. Now, covered entities must provide individuals equal accesspregnancy, pregnancies, high risk pregnancy to health programs and activities without discrimination based on sex, including but not limited to pregnancy, false pregnancy, termination of pregnancy, recovery from childbirth or related medical conditions.

Significantly, HHS extended the term “gender identity” to include gender expression, non-binary gender identities, and transgender status.

V. How will this impact the coverage offered under a Plan?

The Rule does not affirmatively require covered entities to cover any particular procedure or treatment for transition-related care. However, the Rule includes specific protections for transgender individuals and prohibits discriminatory practices. Specifically, HHS stated that “we do not affirmatively require covered entities to cover any particular treatment, as long as the basis for exclusion is evidence based and nondiscriminatory.”

DoctorNote that HHS specified a limited exception to the requirement that covered entities treat individuals consistent with their gender identity: that a covered entity may not deny or limit health services that are ordinarily or exclusively available to individuals of one sex or gender based on the fact that the individual’s sex assigned at birth, gender identity, or gender in a medical or health insurance plan record differs from the one to which such health services are ordinarily or exclusively available. HHS provided the following example:

“[A] covered entity may not deny an individual treatment for ovarian cancer where the individual could benefit medically from the treatment, based on the individual’s identification as a transgender male. HHS notes that blanket exclusions of all gender transition services, which historically have been used by some Medicaid programs and health insurers, are now recognized as outdated and not based on current standards of care.”

VI. When must covered entities post a notice regarding their non-discrimination policies?

Covered entities must post a notice by October 16, 2016, containing certain elements as required by HHS, as described at 45 CFR 92.8. Notices must be available to beneficiaries, enrollees, applicants, and members of the public. They must be printed in a conspicuously visible font and included in significant communications (such as handbooks and outreach publications), in conspicuous physical locations where the entity interacts with the public, and in a conspicuous location on the covered entity’s website accessible from the homepage. HHS has published a sample notice and nondiscrimination statement.

VII. Will covered entities need to implement a grievance procedure specificemployee benefit plans to Section 1557, and if so, are there special considerations or guidelines?

        Covered entities that employ at least 15 people must adopt a grievance procedure that incorporates appropriate due process standards and provides prompt and equitable resolution of grievances under Section 1557.

HHS and covered entities with more than 15 employees also must designate at least one employee to coordinate the entity’s efforts to carry out Section 1557 responsibilities, including the investigation of grievances. The Rule includes a sample grievance procedure.To ensure compliance with Section 1557, HHS will provide covered entities with a training curriculum on key provisions of the rule.

For more information about Section 1557, consult your broker, legal advisor or the Department of Health and Human Services.MedCost 

 

This blog post should not be considered as legal advice.

Health Costs Up 6% for Big Employers in 2017

Big employers expect health costs to continue rising by about 6 percent in 2017, a moderate increase compared with historical trends that nevertheless far outpaces growth in the economy, two new surveys show.

These cost increases, while stable, are both unsustainable and unacceptable,” said Brian Marcotte, CEO of the National Business Group on Health (NBGH), a coalition of very large employers that got responses from 133 companies.

Employers are changing tactics to address the trend, slowing the shift to worker cost sharing and instead offering video or telephone links to doctors, scrutinizing specialty-drug costs and steering patients to hospitals with records of lower costs and better results.

Most large-company employees should expect a 5 percent increase in their premiums next year and, in contrast to previous years, “minimal changes” to plan designs, NBGH said.

(Kaiser Health NewsJay Hancock, August 9, 2016)
Kaiser Health News

What to Do If You Receive This Notice

By Michael Berwanger, JD, Director, Quality Management & Compliance

You may receive a notice from the Health Insurance Marketplace or an Exchange regarding former or current employees who received a tax credit on an exchange. (Click here to view a redacted notice example.)

If you receive such a notice, this communication summarizes the purpose of the notice, why you as an employer are receiving the notice, and what you may need to do in response to the notice. For more information, a detailed Question and Answer document has been provided by the IRS here.

What are the notices?

The notices from the Exchanges are in connection to the employer shared responsibility provisions, sometimes referred to as pay or play” tax provisions, and notify the employer about individual(s) who:

(1) have received a premium tax credit to purchase health insurance on the Exchange, and

(2) who reported the name of their employer during the tax credit application process.

These notices are part of the Exchange verification process under the Affordable Care Act (“ACA”) for determining eligibility for premium tax credits and reduced cost-sharing, and for exemption from the individual mandate tax.

Why would an employer receive these notices?

Tax form & glassesUnder the ACA, certain employers (those with at least 50 full-time employees or full-time equivalents, also known as applicable large employers) might have to pay an employer shared responsibility payment for any month that at least one full-time employee enrolled in Marketplace coverage and received an advanced premium tax credit, or cost sharing reduction. You can read about eligibility thresholds here.

Individuals are only eligible for tax credits on the Health Insurance Marketplace/Exchange if they do not have minimum essential coverage available through their employer, or they are not offered affordable minimum value employer coverage. (Additionally, they must meet specified income and US residency requirements). Thus, employees who have affordable employer coverage available should not qualify for subsidies to buy health insurance in the Exchange.

As part of the application process for a premium tax credit or cost-sharing reduction, an applicant may submit to the Exchange that their employer:

  • did not offer coverage to the employee while employed by the employer,
  • the employer provided coverage but it was not “affordable” or did not provide “minimum value”, or
  • the employee was in a waiting period and unable to enroll in health care coverage. (Please see IRS Notice 2012-58 for an explanation of waiting period rules).

If an Exchange determines that an applicant is eligible to receive an advanced premium tax credit or cost-sharing reduction, and that finding was based at least in part on the above factors, the Marketplace will likely investigate to determine if the employer must pay an employer shared responsibility payment.

Why should an employer pay attention to these notices?

In 2016, employers with at least 50 full-time employees or full-time equivalents are subject to “play-or-pay” penalties if at least one full-time employee receives a subsidy to buy insurance in an Exchange. These notices from the Exchanges alert employers that some of their employees have qualified for premium tax credits and the employer faces potential penalties. Please note that only the IRS, not the Marketplace, can determine whether an employer will owe an employer shared responsibility payment.

health insurance noticesThe notice provides a 90-day response window from the date stated on the notice. Thus, employers will want to respond to the Exchange if they did offer a particular employee coverage that was affordable and provided minimum value, or if the notice is otherwise inaccurate.

What should employers do if they receive a notice?

Employers are not required to respond to Exchange notices, but it will be in an employer’s best interest to respond if the notice is regarding a full-time employee who was actually offered coverage, or if the employee misreported information and was not actually entitled to coverage. If you choose to appeal the notice, you can do so here, at the HealthCare.gov website. Any responses must be made within the 90-day verification process time. Please note that it is likely Exchanges will send notices to whatever employer address the employee provided on his/her application for Exchange coverage.

How can an employer file an appeal?

Employers have 90 days from the date stated on the notice from the Marketplace to file an appeal. This appeal can be filed either by:

  • Completing the Employer Appeal Request Form or:
  • Submitting a letter with the following information:
    • Business name
    • Employer ID Number (EIN)
    • Employer’s primary contact name, phone number and address
    • The reason for the appeal
    • Information from the Marketplace notice received, including date and employee information

Mail the appeal request form or letter, along with a copy of the Marketplace notice, to the following address, or fax the documents to 1-877-369-0129:

Department of Health and Human Services
Health Insurance Marketplace
465 Industrial Blvd.
London, KY 40750-0061

Information supporting your appeal may be included.MedCost

This blog post should not be considered as legal advice. For more information, consult your broker, legal advisor or the Department of Health and Human Services.

Study: 30% of Children’s Hospital Readmissions May Be Preventable

childrens hospital readmissionsOne of the key indicators of the quality of a hospital’s care is how frequently its patients are readmitted within a month after being discharged.

A study this month examined readmission rates for pediatric patients and found that nearly 30% of them may have been preventable.

The study, published online by the journal Pediatrics, reviewed the medical records and conducted interviews with clinicians and parents of 305 children who were readmitted within 30 days to Boston Children’s Hospital between December 2012 and February 2013.

It excluded planned readmissions such as those for chemotherapy. Overall, 6.5% of patients were readmitted during the study period.

The study found that 29.5% of the pediatric readmissions were potentially preventable. In more than childrens hospital readmissionsthree-quarters of those cases, researchers determined that hospital-related factors played a role. A significantly smaller proportion were related to the patient (39.2%), often because of issues that arose after discharge, or the primary care physician (14.5%). (Multiple factors played a role in some patients’ readmissions, so the total exceeds 100%.)

The most common hospital-related reasons had to do with how patients are assessed, postoperative complications or hospital-acquired conditions.

(Kaiser Health NewsMichelle Andrews July 29, 2016)

khn-logo.sm

 

More Employers Are Choosing This Health Plan

Cost & Government Regulations Are Major Factors

If you’re like most employers, covering the costs of your employees’ health care is a major concern. Expenses for employee hospitalizations, chronic diseases and drug costs are threatening to swallow up annual profits for businesses.

Employer-sponsored health premiums rose 203% between 1999 and 2015.[i] This is why more employers are choosing high-deductible health plans (HDHP), as the graph below shows. Is it possible to manage health care costs and still do business?

HDHP

 

What Is an HDHP?

A high-deductible or consumer-driven health plan has lower premiums and higher deductibles than traditional insurance plans.[ii] Instead of copays, a covered employee would pay health costs until the deductible is met.

Many companies offer a Health Savings Account (HSA) or a Health Reimbursement Account (HRA) that offers significant tax advantages for both employers and employees. The HDHP combined with HSA or HRA contributions can shelter income from taxes while helping to keep premiums low.

HDHP

Benefits

How can your Human Resource department explain this shift in benefits, when only 12% of adults have a basic understanding of health terms?[iii] Here are some real benefits to tell employees when migrating to an HDHP:

  1. “Your income tax will be lower.” Employees contributing to an HSA will shelter that income from federal taxes. This can add up to 39.6% in savings, depending on the tax bracket. Can anyone say “free money”? Especially when companies add their contributions to an HSA if an employee participates in the program.

2. “You will have more control over how you spend your health dollars.” One reason HDHPs are also called “consumer-driven” is because employees have choices about where they shop services. If the same treatment for a respiratory infection can be obtained by a telemedicine call instead of the family doctor, out-of-pocket savings can really add up. And many employers offer price comparisons for services that allow smarter choices before getting treatment.

3.  “You will have an automatic nest egg for health expenses.” It’s not easy to save, but payroll deductions can ease planning for costs. And the beauty of HSAs is that employees take this account with them, even if they change jobs. HRAs reimburse qualified medical expenses up to a fixed amount each year — another tax-free savings funded by employers, which can be rolled over to be used in subsequent years.

Summary

Employer health benefits, health care, employee claimsIn this tumultuous era of health care, employees are gaining an increasing amount of financial responsibility. This gives smart employers the opportunity to treat your staff as partners in decision-making.

Educating your employees is a key foundation to bridging the transition to HDHPs as a benefits option. The next blogs will provide important steps to make that transition successfully, and how to manage expectations during the change.

 

To print this article, click on the title and scroll to “PRINT THIS PAGE” at the bottom.

 

[i]  “Recent Trends in Employer-Sponsored Health Insurance Premiums,” Kaiser Family Foundation, January 5, 2016, http://kff.org/infographic/visualizing-health-policy-recent-trends-in-employer-sponsored-health-insurance-premiums/ (accessed June 16, 2016).

[ii] High Deductible Health Plan (HDHP), HeathCare.gov Glossary, https://www.healthcare.gov/glossary/high-deductible-health-plan/ (accessed June 29, 2016)

[iii] Quick Guide to Health Literacy Fact Sheet, http://health.gov/communication/literacy/quickguide/factsbasic.htm (accessed June 29, 2016)

 

The Employer Benefit First Offered by NASA

The first place this employer benefit was offered wasn’t even on planet Earth.telemedicine employers

The idea to assess human health from afar started with NASA in the early 1960’s. Both American and Russian doctors were concerned that astronauts might lose circulation and other functions in space. The first telemedicine was practiced on animals attached to medical monitors while orbiting Earth.

TV viewers became familiar with live updates on astronauts’ heart rates, breathing and temperature during space flights. And the technology has translated right into employer benefit plans for medical care for onsite and offsite workers.

Over 15 million Americans obtained medical care remotely in 2015,[i] and the American Telemedicine Association anticipates 30% growth in 2016. Employers have picked up on the cost savings and convenience—nearly 75% of large employers plan to offer telemedicine as a health plan benefit in states that regulate this method, up from 48% in 2015.[ii]

telemedicine employers

Why Telemedicine?

Employers are searching for ways to contain the spiraling costs of health care. The ability for employees to make a call or have a video conference with a board-certified doctor within minutes brings both convenience and less time away from work. A recent analysis by Willis Towers Watch estimated that as much as $6 billion per year could be saved by U. S. companies using telemedicine.[iii]

Where the Savings Come From

Employers are seeing the need to educate employees about the best medical options for every health need. Some fevers, headaches, sore throats and other minor symptoms are appropriate for a telemed call (see “Treatment Alternatives to the Emergency Room”). Average cost: $45.

Compare the cost of a telemed call with an average primary care doctor visit: $145. Or the average cost of an ER visit: $1,316. [iv] Your employees with commutes to work may have to travel longer distances for in-person visits—time also lost in productivity. And many employees allow conditions to worsen before seeking treatment, resulting in even higher expense and time away from work.

“Over 400 million visits a year are appropriate
for telehealth.”

 – Jason Gorevic, Teladoc CEO, NJTV News

Managing Costs in a Complex Environment

As responsibility for paying health bills shifts to the employee, 24/7 services such as Teladoc becometelemedicine employers an increasingly attractive option for appropriate levels of medical care. A board-certified doctor is always available with a cell phone callback, even if an employee is on vacation or lives in a rural area where medical access is more limited.

MedCost clients who use Teladoc have already saved hundreds of thousands of dollars in 2016, avoiding more expensive treatment centers and lost hours at work.

Looming in employers’ minds is the Affordable Care Act’s Cadillac tax, now postponed until 2020. This 40% excise tax would trigger when an employer offers health benefits above $10,200 for an individual and $27,500 for a family.

Employers have already begun to raise employee deductibles and out-of-pocket costs, not included in the value of a health policy.

Summary

Some large employers such as JetBlue Airways are installing telemed kiosks at their workplaces, harnessing technology innovations for immediate care.[v] The Department of Veteran Affairs provided telemedicine employerstelemed services to more than 675,000 veterans in fiscal 2015. Employees who are used to searching for restaurants and shopping deals on cell phones will increasingly call a doctor to get routine medical care.

And it won’t even require a trip to outer space to get it.

 

[i] Melinda Beck, “How Telemedicine Is Transforming Health Care, Wall Street Journal, June 27, 2016, http://www.wsj.com/articles/how-telemedicine-is-transforming-health-care-1466993402 (accessed July 14, 2016)

[ii] National Business Group on Health, “Health Care Benefits Cost Increases to Hold Steady in 2016,” August 12, 2015, https://www.businessgrouphealth.org/pressroom/pressRelease.cfm?ID=263 (accessed July 18, 2016)

[iii] Willis Towers Watson, “Current Telemedicine Technology Could Mean Big Savings,” August 11, 2014, https://www.towerswatson.com/en-US/Press/2014/08/current-telemedicine-technology-could-mean-big-savings (accessed July 15, 2016)

[iv] Sabrina Rodak, “Study: 71% of ED Visits Unnecessary, Avoidable,” Becker’s Hospital Review, April 25, 2013, http://www.beckershospitalreview.com/capacity-management/study-71-of-ed-visits-unnecessary-avoidable.html (accessed February 23, 2016)

[v] Phil Galewitz, “Kaiser: Your Doctor Will See You Now,” June 20, 2016, http://www.usatoday.com/story/news/2016/06/18/kaiser-how-far-telemedicine-has-come/86084092/ (accessed July 18, 2016)

How to Turn Health Care Data into Dollars

Is your company one of the growing numbers of US employers using health care data to manage expenses?

Just as employers keep a close watch on profit and loss columns, the same analysis is now available for companies’ health care costs. Big data is increasingly driving improved, better coordinated care to improve employee health while managing spiraling expenses.

We know this is a complicated topic (just like health care). That’s why we’re offering a free white paper examining the role of big data in health care and how employers can achieve true quality, cost-effective outcomes.

Between 1999 and 2015, employer-sponsored health premiums rose 203%.[i] Managing employee health costs is becoming more and more difficult every year.

Big data compiles massive amounts of data from multiple sources, yielding key metrics and predictive analytics for health care providers. Providers can then leverage this into interventions that provide high quality, cost-effective care. And employers who receive regular reports on trends can work with a benefits administrator to better manage those costs while supporting employee health outcomes.

Jane’s Story

diabetic, advanced analytics, big dataHere’s an example of how MedCost applies this analysis. Jane,* a 42-year old female member with moderately-controlled diabetes, has health benefits through her job. Jane’s biannual visit to her Primary Care Physician (PCP) documents her routine lab work, prescriptions and referrals for preventive screenings.

Between PCP visits, this diabetic member gets the flu, causing severe increases in blood glucose levels. When Jane goes to the Emergency Room, the ER doctor increases her medication dosage. After she goes home, Jane’s personal blood glucose meter shows an alarming drop in her blood sugar levels. Jane calls her PCP, who adjusts her dosage to prevent more complications. Jane’s next checkup is planned in six months.

Was all the data communicated from the hospital’s electronic records, the lab vendor’s system, payer claims and her home monitoring glucose meter? Will the PCP be able to verify that Jane actually obtained her preventive mammogram or flu vaccine prescribed before the ER visit?

At MedCost, Jane’s case would be carefully monitored by her nurse health coach. If there is an issue, her nurse health coach would follow up.

white paper

Chronic illnesses like Jane’s need expert support to prevent worse outcomes and resulting higher costs. And advanced analytics can now identify patients and populations at risk for developing certain conditions prior to the actual onset of illness.

 The white paper, Transforming Data into Dollars, offers an understanding of factors influencing the need for advanced analytics solutions, including an example using the MedCost Care Management programs.

Here are other insights from the white paper:

BENEFITS OF ADVANCED ANALYTICS  
   
1.     Accurate Reporting Normalized measures based on industry-accepted tools of evaluation yield best results for your employees.
2.     Maximized Outcomes Your company will rate higher on the Analytics Sophistication Scale and outperform industry peers.
3.     Healthier Employees Potential risk for developing conditions can be identified and prevented.
4.     Lower Costs Wise management of expenses creates a sustainable long-term cost trend.

  We’ve identified high-risk employees, improved health results and minimized costly hospital visits using precise data analysis in a sample case study that illustrates these key benefits. Download our white paper to learn how.

white paper

*Actual patient data not used.

[i] “Recent Trends in Employer-Sponsored Health Insurance Premiums,” Kaiser Family Foundation, January 5, 2016, http://kff.org/infographic/visualizing-health-policy-recent-trends-in-employer-sponsored-health-insurance-premiums/ (accessed June 16, 2016).

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DOL Increases Employee Benefit Plan Penalties

By Michael Berwanger, JD, Director, Quality Management & Compliance

employee benefit plansOn June 30, the Department of Labor (DOL) announced two interim final rules that increase civil penalties for various violations as required by the Federal Civil Penalties Inflation Adjustment Act Improvements Act of 2015.

The Act requires agencies to: 1) adjust the level of civil monetary penalties with an initial “catch-up” adjustment; and (2) make subsequent annual adjustments for inflation. According to the DOL, future adjustments will be made by January 15 of each year, starting in 2017. Here are some highlights of the changes:

*Form 5500The maximum penalty for failing to file Form 5500, which must be filed by most Employment Retirement Income Security Act (ERISA) plans, will increase from $1,100 to $2,063 per day that the Form 5500 is late.

*Group Health Plans. The maximum penalty for failing to provide the summary of benefits and coverage (SBC) required under health care reform will increase from $1,000 to $1,087 per failure. Violations of the Genetic Information Nondiscrimination Act (GINA), such as establishing eligibility rules based on genetic information or requesting genetic information for underwriting purposes, may result in penalties of $110 per participant per day, up from $100. Maximum penalties relating to disclosures regarding the availability of Medicaid or Children’s Health Insurance Plan assistance, including failure to disclose to a state, on request, relevant information about the employer’s plan, will also increase from $100 to $110 per day.

*401(k) Plans. For plans with automatic contribution arrangements, penalties for failure to provide the employee benefit plansrequired ERISA § 514(e) preemption notice to participants will increase from $1,000 to $1,632 per day. Penalties for failing to provide blackout notices (required in advance of certain periods during which participants may not change their investments or take loans or distributions) or notices of diversification rights will increase from $100 to $131 per day. And the maximum penalty for failure to comply with the ERISA § 209(b) recordkeeping and reporting requirements will increase from $11 to $28 per employee.

*Multiple Employer Welfare Arrangements (MEWAs)Penalties for failure to meet applicable filing requirements, which include annual Form M-1 filings and filings upon origination, will increase from $1,100 to $1,502 per day.

Other penalties increased by the regulations include those for failure to provide certain information requested by the DOL, failures not corrected within specified time periods, and defined benefit plan compliance failures. The increases apply to penalties assessed after August 1, 2016, with respect to violations occurring after November 2, 2015.

employee benefit plansPenalty assessments made before August 1, 2016, (including those relating to violations after November 2, 2015) and assessments at any time relating to violations on or before November 2, 2015, will reflect the lower pre-adjustment amounts.

You can read the DOL FAQ here and see a full listing of new penalty amounts here.

 

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