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Boca Benefits Consulting Group Inc.
The Insight
BBCG Consultants - Creating The Best Teams For The Task At Hand Since 1980
(727) 510-7138
Copyright © 2008 Boca Benefits Consulting Group, Inc. | All Rights Reserved | Clearwater, Florida USA | |
 Issue: 11.15.7 Special |
Tuesday, November 4, 2008 |
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| Below is critical reading for Owners, CEO's, CFO's, HR Directors, and Benefits Managers.
Action required by policyholders of BCBS of Florida if an "opt out" decision is made.
May require action by policyholders of other group insurance carriers.
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Age 30 Eligibility In Florida Health Plans
BCBS of Florida Takes Position
Self-Funded Groups Without ERISA Exemption Included |
 The below pane is a reprint of our recent The Insight Special Edition pertaining to Florida SB 2534 which calls for health plan eligibility of certain dependents beyond the age of 25. Please also see our blog entry on this subject by clicking here. As we receive additional information on this subject, it will be posted immediately as a comment to the blog post linked above.
In our last edition we indicated that some clarification from Florida's Department of Insurance Regulation was pending. Blue Cross Blue Shield of Florida has been leading the charge in terms of securing additional information on the implementation requirements.
Below is an excerpt from a letter template that BCBS of FL will be sending to Florida group policyholders. BBCG received it on 11/3/2008.
The State of Florida recently passed Senate Bill 2534, expanding coverage for eligible dependent children up to 30 years of age who meet certain criteria. The law is effective October 1, 2008 and insurers are required to offer this coverage to all policyholders or certificateholders.
Blue Cross and Blue Shield of Florida, Inc. (BCBSF) and Health Options, Inc. (HOI) are offering this coverage to all of its group policyholders and are encouraging employers to include coverage for dependents who meet the eligibility criteria included in this bill. Member handbooks are currently being endorsed to include coverage for eligible dependent children between the ages of 25 and 30 who meet the eligibility criteria for continued coverage.
To date BCBS of FL has taken a different position than some of the other major managed care carriers. Whereas, at least two of the other major carriers consider the statute to be a mandate that this new eligibililty provision must be included in all Florida health plans not otherwise exempted under ERISA, BCBS of FL appears to take the position that eligibility provision wording under the statute is such that the provision only needs to be made available and that the policyholders can opt out of the requirement if they so choose.
Before any action is taken either way, we strongly recommend that you be aware of this discussion as it further develops. In the case of BCBS of FL, they have indicated that the opt out must be an active request. Passive silence on the issue will be construed to mean that the change was requested and policies will automatically be ammended. Other carriers may also be making last minute changes in their protocols relative to the new statute which makes it more critical to employers during this year-end enrollment period.
Why Is This Important To You?
If you are a small employer the impact may be minimal at first. However, this ultimately could constitute a major cost shift from other payor modalities (i.e., Medicaid, Medicare, etc.) as high amount claimants join the commercial small group experience pool and small group rating is driven up.
If you are a mid-size to large employer whose annual rating runs at least to some degree off the actual claims experience of your group, the impact could be more direct and could occur more quickly if those in the 25-30 age group are less healthy than your average (i.e., the risk of "adverse selection" among the newly eligible).
If you are a large self-funded employer, but do not fall under the protection of the ERISA exemption umbrella, this is a state mandate that is applicable to your group. Unlike other state insurance mandates, public sector entities, church groups, etc., fall under the new statute.
Please forward this article to an HR or Benefits professional by clicking on either the upper right or lower left Forward Email links.
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[For Florida Plans Only -- New State Regulation -- Some State Clarification Pending -- 10/1/2008 Effective Date]
The below legislation is applicable to all insured medical plans and all self-insured plans not otherwise exempted under ERISA (i.e., governmental, church, etc.). It is not applicable to stand alone products such as dental or vision. As of this writing the major health carriers in Florida have requested further clarification and have indicated that the protocols established to implement it on its effective date may be subject to change.
Dependent coverage legislation (FL SB 2534) enacted by the State of Florida became effective on October 1, 2008. In new plans starting on or after this date, eligible dependents will have the option to maintain dependent coverage up to the end of the calendar year in which the dependent reaches his or her 30th birthday. For existing plans, the option to offer coverage will occur on the next renewal date after October 1, 2008. In addition, there is a special open enrollment period between October 1, 2008 and April 1, 2009 for dependents who aged out of their plans prior to October 1, 2008.
A dependent child between the ages of 26 and 30 may request to continue as a dependent on his or her parent's coverage even after the child reaches the limiting age under the terms of the policy if he or she:
- Is not yet 30 years old
- Has no children
- Is a resident of Florida or, if not a Florida resident, is a full or part-time student at an accredited institution of higher education
- Is not eligible for Medicare and is not actually covered under another group health plan.
The employee may make the request to continue the dependent child's coverage:
- When he or she reaches the limiting age, or
- During the open enrollment period for the group of which the parent is a member on or after October 1, 2008.
If you have not been contacted by your carrier rep or broker about this important change in policy wording, please contact us and we will intercede on your behalf.
Our blog RSS feed is: http://bocabenefits.com/blog/?feed=rss2
Please use the icon at the top or the link at the bottom to forward this e-newsletter to an HR or a Benefits professional
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About Boca Benefits Consulting Group, Inc.
BBCG, Inc. has been providing brokerage and consulting services to Florida employers since its formation in 1996. Its principal consultant, Robert W. Murphy, has 28 years of insurance carrier management and consulting experience. He holds an advanced financial degree and four of the most prestigious financial services designations in the industry (REBC, ChFC, CLU, RHU). He has been a panelist/speaker at a national conference on the future of healthcare and was a participant at a Harvard University executive program entitled "Skills for the New World of Health Care."
Please click here for additional contact information.
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