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Health Care Reform Update
HHS Guidelines | PPACA Compliance
| August 24, 2011 |
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Greetings!
Health Care reform (aka PPACA) news keeps rolling out as HHS issues guidance, guidelines and deadline reminders. For instance, State Insurance Exchanges. We're assured (by HHS) these Exchanges will make finding the right coverage easier for consumers, as well as more affordable. I've yet to see anything affordable about health reform, but we'll see. In the meantime, we at EmSpring hope the update provides useful insight and information around PPACA. Please don't hesitate to give us a ring if you'd like to chat more about it.
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| Women's Preventive Care Under New HHS Guidelines | |
HHS has issued new preventive care guidelines for women, effective for plan years beginning on or after August 1, 2012. As you may be aware, the PPACA has a preventive care mandate that requires non-grandfathered health plans to cover preventive health services without cost-sharing requirements for the services. Under the n ewly issued HHS guidelines, preventive care like well-woman visits, breastfeeding support, domestic violence screening and contraceptives are covered without a co-payment, deductible or co-insurance.
Note: the preventive care mandate doesn't apply to grandfathered plans, only non-grandfathered ones. For more on the PPACA's preventive care mandate, and how it may affect your plan or your care, either visit the healthcare.gov site or read the complete EmSpring Legislative Brief summary document.
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HHS Proposed Guidance on State Insurance Exchanges
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In July, HHS announced two notices of proposed rulemaking: (1) Establishment of Exchanges and Qualified Health Plans, and (2) Standards Related to Reinsurance, Risk Corridors and Risk Adjustment. Though the proposed guidance isn't final, it's intended to help states design and implement their Exchanges as they:
- Set standards for establishing the Exchanges, set up a Small Business Health Options Program (SHOP), perform the basic functions of an Exchange and certify health plans to participate in the Exchanges
- Ensure premium stability for plans and enrollees in the Exchanges
HHS says that the proposed guidance creates minimum standards for the Exchanges, while also giving states flexibility so they can build Exchanges that work for their particular markets. The idea (and expectation) is that the Exchanges will provide a competitive market for health insurance, making it more affordable for consumers. Structure-wise, while a state may have more than one Exchange operating regionally in two or more states, the Exchanges can't overlap. The state may also choose to have a local Exchange only. Regardless, each state must ensure that the entire state is covered by at least one Exchange.
The already complex situation around Exchanges is made more confusing by the commercial "exchanges" already in play in some states - Washington included - that do not fall under these rules. Washington's Health Care Authority has placed organizational design responsibility for its Exchange with Molly Voris.
Our EmSpring Legislative Brief provides a good summary of the proposed guidance, or you can read through the more lengthy HHS version here. Note: HHS is accepting public comments on the proposed Exchange guidance for 75 days to learn from states and other stakeholders how the rules can be improved.
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Open Enrollment PPACA Compliance Reminders
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With the onset of the PPACA came many changes for you and your health plan. You felt the impact of a number of them effective September 2010. Whether your plan is a grandfathered or non-grandfathered plan, be sure to review applicable effective dates. A few reminders as we move toward new deadlines:
Annual Limits
- If you want a waiver of the limits on essential benefits, be sure to apply for it before the waiver program closes to applications on September 22, 2011.
- Annual limits will be phased out over the next 3 years.
- Plans that began on or after September 23, 2010 could have a minimum annual limit of $750,000.
- If your plan year begins on or after September 23, 2011, you may impose a minimum annual limit of $1.25 million.
- Beginning on or after September 23, 2012 and prior to January 1, 2014, plans may impose a minimum annual limit of $2 million.
Other Reminders
- Assure that pre-existing condition exclusions for children under age 19 are eliminated.
- Be sure your plan reflects no lifetime limits on essential benefits and allows those who may have previously reached the limit to re-enroll, unaffected.
- If a non-grandfathered plan, be sure patient protections, such as no requirements for preauthorization or referral for OB/GYN care, or for emergency services, are included.
- Non-grandfathered plans also must eliminate the increased coinsurance or copayment requirements for out-of-network services.
We know that a proper plan review is a painstaking process. Call on your EmSpring team to help tackle the task!
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|  | "What the PPACA (health reform law) says and what people think it says
are often two entirely different things."
Dan Fisher
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| Our Association | |
HRBA is now
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EmSpring is a professional services firm; employee-owned and client driven. Please let us know if we can help you with your employee benefits, human resource technology, or payroll integration needs. We'll be here when you need us.
Sincerely,
Dan Fisher, CEO EmSpring Corporation |
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