A Pharmacist Looks at the Opioid Epidemic

By Zafeira Sarrimanolis, PharmD, MedCost Clinical Consultant

The statistics prove it — more Americans die from accidental drug overdoses each year than from traffic accidents. Data from 2014 showed more deaths from drug overdoses than any other year on record.[i]  Approximately six out of 10 of those deaths involved opioids.[ii]

opioid epidemicSource: Centers for Disease Control and Prevention[iii]

The week of September 18-24 was designatedPrescription Opioid and Heroin Epidemic Awareness Week.”[iv] As a pharmacist, I know that opioid medications can be beneficial in controlling certain types of pain. However, this benefit must be weighed against the risks associated with these medications.

The Epidemic

The number of opioid prescriptions in the US quadrupled from 1999 to 2014, while the number of American reporting chronic pain remained constant.[v]

Opioid pain medications like Opana, OxyContin and Percocet were originally used to treat short term-pain, such as after a surgery or accident, and for long-term pain associated with cancer. Today, we see these medications prescribed and utilized more commonly for all forms of pain and over longer periods of time.

The diagram below highlights opioid prescribing patterns in the US. In some states, including NC, the number of painkiller prescriptions per 100 people is equal to or exceeds 100.[vi]

opioid epidemicThere are many sources of misused opioid prescriptions. The majority, approximately 60%, of misusers obtain opioid medications from a friend or relative, either for free, by stealing or by buying them.[vii] 

 

The Dangers

Imagine you are in a car accident and have persistent back pain that makes it difficult for you to sit and stand

comfortably. The doctor prescribes an opioid medication used regularly to control your pain.  Soon you find that you have become dependent on this medication—even after your back feels better.

This scenario happens more often than we think. The danger of opioids is that they can become addictive to any user. For this reason, they should only be prescribed in appropriate cases.

In addition to risk for addiction, these medications are dangerous because of side effects like sedation and respiratory depression. These effects can be compounded when combined with other medications. For example, a common drug interaction with Xanax (a medication used for anxiety) can lead to slowed breathing, oversedation and possible death.

Action Steps

The fight against the opioid epidemic requires action from everyone. Prescribers and pharmacies are more regularly monitoring those taking opioid medications. In North Carolina, the Board of Medicine and Board of Pharmacy have strategies to control these medications to decrease utilization and death from opioid abuse and overdose.

The opioid reversal agent, naloxone, is more readily available from retail pharmacies. Efforts are being made to increase access to treatment for addiction. Communities are educating the public on the dangers of opioids and offeopioid epidemring “take-back” programs for disposal of unused opioid medications.

In July, the US Senate passed the Comprehensive Addiction and Recovery Act, the first major federal legislation on addiction in 40 years. The purpose of this law is to expand education, strengthen state monitoring programs and create new treatment programs.

Real progress can only result when doctors, nurses, pharmacists, patients, government officials, community leaders and the family and friends of those affected work together to put an end to the opioid epidemic.

Pharmacist on Staff for Clients

As the new MedCost Pharmacist, I discuss pharmacy management strategies with clients and brokers to control the explosion of drug costs. Prior authorizations, step therapy programs and quantity limits can be frustrating and disruptive. But we know that these utilization management strategies are key in controlling costs. 

Our partnership with OptumRx, ensures that members take safe, effective medications appropriate for their conditions, while implementing cost-saving strategies.

Opioid epidemic

 

 

 

 

 

 

 

 


Source: 
Mercer National Survey of Employer-Sponsored Health Plan -2015l[i]

Our goal at MedCost is to help ensure that our clients’ covered members are being treated appropriately and safely, without the risk of exorbitantly high costs. This will not only be the most cost-effective strategy, but it can result in members with healthier, happier lives.MedCost

 

[i] “The Opioid Epidemic: By the Numbers,” US Health & Human Services, June 15, 2016, http://www.hhs.gov/sites/default/files/Factsheet-opioids-061516.pdf (accessed September 26, 2016)

[ii] “Injury Prevention & Control: Opioid Overdose,” Centers for Medicaid and Medicare Services, https://www.cdc.gov/drugoverdose/data/index.html (accessed September 22, 2016).

[iii] Ibid.

[iv]Office of the White House Press Secretary, September 16, 2016, https://www.whitehouse.gov/the-press-office/2016/09/16/presidential-proclamation-prescription-opioid-and-heroin-epidemic (accessed September 22, 2016).

[v] Guideline for Prescribing Opioids for Chronic Pain, Centers for Medicaid and Medicare Services, March 16, 2016, http://www.cdc.gov/mmwr/volumes/65/rr/rr6501e1.htm (accessed September 22, 2016).

[vi]  “Injury Prevention & Control: Opioid Overdose,” Centers for Medicaid and Medicare Services, http://www.cdc.gov/drugoverdose/data/prescribing.html (accessed September 22, 2016).

[vii] Ibid.

[viii] Bruce Lee, “With the Excise Tax in Their Sights, Employers Hold Health Benefits Cost Growth to 3.8% in 2015,” Mercer, November 19, 2015, http://www.mercer.com/newsroom/national-survey-of-employer-sponsored-health-plans-2015.html (accessed September 22, 2016).

5 Key Definitions in Health Plans

How many of the terms in this example below do your employees understand? If you’re getting blank stares over words like “co-insurance” and “out-of-pocket limit,” it’s time to educate your staff before open enrollment starts for the next plan year.

definitions health plans

Source: Centers for Medicaid & Medicare Services

 

Five Key Terms

Only 12% of American adults have a basic understanding of the terms used in their health plans.[i] As more health plans are transitioning to some type of Consumer-Driven Health Plan (CDHP), it is more vital than ever for employees to understand basic terms that identify their responsibilities for payment.

Here are five easy definitions for HR professionals to use when explaining your company health plan:

  1. Deductible

The amount an employee owes for health care services before the health indefinitions health planssurance or plan begins to pay. For example, if a deductible is $1,500 as in Jane’s example above, the plan won’t pay anything until a $1,500 deductible for covered health care services is met. The deductible may not apply to all services.[ii]

2. Co-payment

A fixed amount (e.g., $25) that an employee pays for a covered health care service, usually when service is received. The amount can vary by the type of covered health care service. Co-payments are more familiar in traditional plans such as Preferred Provider Organizations (PPOs).

3. Network

The facilities, providers and suppliers your health plan has contracted with to provide health care services. So in-network services or providers have already negotiated a billing rate that would be applied.

Out-of-network charges are usually more expensive, because no rate has been contracted with that doctor’s office or provider.

4. Out-of-Pocket Limitemployee deductibles

The most an employee pays during a policy period (usually a year). This limit usually includes deductibles, copays and/or co-insurance. Premiums, balance-billed charges or health care not specified in the plan would not be included.

5. Co-insurance

An employee’s share of the costs of a covered health care service, calculated as a percent (for example, 20%) of the allowed amount for the service.

In the example above, after Jane met her deductible ($1,500), her plan began to pay 80% of qualified health expenses. Jane’s part of the payment (co-insurance) was 20%, paid until Jane’s total expenses for the year hit her $5,000 out-of-pocket limit.

After Jane had paid a total of $5,000, her plan paid all other expenses for the rest of the plan year.

 

Equip Your Employeesdefinitions health plans

As HR departments approach a new year, health plan terms may still sound like a language most employees don’t know. Equip your employees to make decisions they will feel good about so they can better manage those vital health care dollars.MedCost

 

 

[i] Quick Guide to Health Literacy Fact Sheet,http://health.gov/communication/literacy/quickguide/factsbasic.htm (accessed September 13, 2016)

[ii] Centers for Medicare & Medicaid Services https://www.cms.gov/CCIIO/resources/files/downloads/uniform-glossary-final.pdf (accessed September 13, 2016)

 

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Employee Deductibles Rise Faster Than Wages

ks110111-medEmployer health insurance expenses continued to rise by relatively low amounts this year, aided by moderate increases in total medical spending but also by workers taking a greater share of the costs, new research shows.

Average premiums for employer-sponsored family coverage rose 3.4% for 2016, down from annual increases of nearly twice that much before 2011 and double digits in the early 2000s, according to a survey by the Kaiser Family Foundation. (Kaiser Health News is an editorially independent program of the foundation.)

But 3.4% is still faster than recent economic growth, which determines the country’s long-run ability to afford health care.

And the tame premium increases obscure out-of-pocket costs that are being loaded on employees in the form of higher deductibles and copayments. Another new study suggests those shifts have prompted workers and their families to use substantially fewer medical services.

For the first time in Kaiser’s annual survey, more than half the workers in plans covering a single person face a deductible of at least $1,000. Deductibles for family plans are typically even higher.

Deductibles are what consumers pay out of pocket before the insurance kicks in. Employers sometimes contribute to pre-tax accounts to help workers pay such costs.

Employers have been flocking to high-deductible plans in recent years, arguing that exposure to medical costs makes consumers better shoppers.wingeddollar-sm

It also saves employers money. Having workers pay more out of pocket shaved half a percentage point off premium increases of employer-sponsored plans in each of the past two years, Kaiser researchers calculated.

Since 2011, the average deductible for single coverage has soared 63%, according to the survey, while workers’ earnings have gone up by only 11%.

Microsoft PowerPoint - 20160825 Cumulative Slides [Read-Only]

 

 

(Kaiser Health News, Jay Hancock and Shefali Luthra, September 14, 2016)

 

Federal Study Helps Seniors Stay at Home

seniors stay homeA federally-funded project that researchers say has potential to promote aging in place began by asking low-income seniors with disabilities how their lives at home could be better, according to a study released Wednesday.

At the end of the program, 75% of participants were able to perform more daily activities than they could before and symptoms of depression also improved, researchers said in the journal Health Affairs. 

Called Community Aging in Place, Advancing Better Living for Elders, or CAPABLE for short, the program was funded by the Center for Medicare & Medicaid Innovation.

The seniors who took part were each paired with a team for five months that included an occupational therapist, who made six visits; a registered nurse, who made four; and a handyman, who worked a full-day at the participant’s home installing assistive devices and doing repairs, according to the study.

The nurses and therapists helped participants identify three achievable goals for each member of the team and identify what barriers had to be overcome. For example, the therapist might survey a house for safety issues such as unsafe flooring, poorly lit entrances and railings in disrepair.

seniors stay homeThe therapist then worked with the elderly person to identify assistive devices, repairs or modifications that could help achieve the participant’s goals. Next, the therapist created a work order for the handyman that prioritized those goals within a $1,300 budget for each dwelling.

Spending on assistive devices and home repairs ranged from $72 to $1,398 for each participant, the researchers said.

They studied 234 adults older than 65 who participated in CAPABLE, all eligible for both Medicare, the government health insurance plan for seniors, and Medicaid, the government health insurance plan for low-income people.

All participants had trouble with routine tasks in a group of eight known as activities of daily living. They include bathing, dressing, using the toilet and walking across a small room. On average, participants had trouble with 3.9 tasks at the start, but improved to just two by the end of the program.

Researchers said they could not conclude that the participants’ improvements were due to the CAPABLE program because the project was funded without a control group to make scientific comparisons.

(Kaiser Health News, Rachel Bluth, September 7, 2016)
KHN

 

Some ACA Insurance Markets in Turmoil

NC and SC Could Be Two of the Most Affected States

ACA insuranceSome of the Affordable Care Act’s insurance marketplaces are in turmoil as the fourth open enrollment season approaches this fall, but what’s ahead for consumers very much depends on where they live.

Competition on these exchanges will be diminished next year when three of the nation’s largest health insurers — Aetna, United Healthcare and Humana — will sell individual plans in many fewer markets. So too will several Blue Cross and Blue Shield plans in various states. That’s on top of the 16 nonprofit co-ops that have closed since January 2015.

The announcements, however, apply generally only to the individual market. The much larger market of employer-sponsored insurance is not part of the health law exchanges.

Most hurt will be marketplace consumers in Arizona, North and South Carolina, Georgia and parts of Florida, where only one or two insurers will be left when open enrollment season begins Nov. 1.

(Kaiser Health News, Phil Galewitz, August 18, 2016)
KHN

The Life-Saving Resource Ignored After Heart Attacks

childrens hospital readmissionsCHARLOTTESVILLE, Va. — Mario Oikonomides credits a massive heart attack when he was 38 for sparking his love of exercise, which he says helped keep him out of the hospital for decades after.

While recovering, he did something that only a small percentage of patients do: He signed up for a medically supervised cardiac rehabilitation program where he learned about exercise, diet and prescription drugs.

“I had never exercised before,” said Oikonomides, 69, who says he enjoyed it so much he stayed active after finishing the program.

Despite evidence showing such programs substantially cut the risk of dying from another cardiac problem, improve quality of life and lower costs, fewer than one-third of patients whose conditions qualify for the rehab actually participate. Various studies show women and minorities, especially African Americans, have the lowest participation rates.

“Frankly, I’m a little discouraged by the lack of attention,” said Brian Contos, who has studied the programs for the Advisory Board, a consulting firm used by hospitals and other medical providers.

ManWithHeartNow, though, advocates say cardiac rehab may gain traction, partly because the federal health care law puts hospitals on a financial hook for penalties if patients are readmitted after cardiac problems. Studies have shown that patients’ participation in cardiac rehab cut hospital readmissions by nearly a third and saved money.

The law also creates incentives for hospitals, physicians and other medical providers to work together to better coordinate care.MedCost

(Kaiser Health News, Julie Appleby, August 31, 2016)

KHN

 

 

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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