Preventive Care Services Regulations
Released
Non-Grandfathered
Plans Must Provide First Dollar Coverage for Preventive Services
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The IRS, DOL and HHS (The Agencies) have jointly released
regulations (The Regulations) regarding the preventive care coverage
requirements contained in The Patient Protection and Affordable Care Act of
2010 (ACA). The Regulations, which were published in the Federal Register on July 19th, define the preventive health
services that a health plan must cover with no cost-sharing
requirements such as a copayments, coinsurance, or deductibles. The rules do not apply to grandfathered
health plans. Required preventive services fall into four (4) categories: - Evidence-based items or services
rated "A" or "B" in the current recommendations of the United States Preventive
Services Task Force.
- Immunizations for routine use in
children, adolescents, and adults with a recommendation from the Advisory
Committee on Immunization Practices of the Centers for Disease Control.
- With respect to infants, children,
and adolescents, evidence-based preventive care and screenings included in
guidelines supported by the Health Resources and Services Administration.
-
With respect to women,
evidence-based preventive care and screenings included in guidelines supported
by the Health Resources and Services Administration.
A health plan is allowed to use reasonable medical
management techniques to determine specific coverage levels related to
frequency of service, care setting, or methods of treatment, if the
recommendations in force do not define these aspects of the required preventive
services. General Description of Covered Services Targeted to the PublicComprehensive List of Services and Recommendations Included in All of the CategoriesOut-of-network
providersFor plans that include in and out of network providers, cost
sharing such as co-pays and deductibles can continue to apply to services
provided by out-of-network providers. Office visitsThe Regulations also provide guidance and examples as to how
preventive services must be covered depending on how the service is billed by
the provider. In other words, if a covered
preventive care service is billed separately from an office visit, then the
plan may impose cost-sharing requirements with respect to the office visit, but
not the charge for the preventive service. On the other hand, if a covered preventive service is not billed
separately from the office visit, and the primary purpose of the office visit
is the delivery of the preventive service, then a plan may not impose
cost-sharing requirements with respect to the entire office visit. Cost ImpactThe Regulations include an estimate of the cost impact the
required services will have on health plan premiums. While the cost impact on any particular plan
will obviously depend largely on what preventive benefits are currently
offered, overall the analysis predicts an average premium increase for all
individual and group plans of 1.5%. It
is expected that individual plans will experience increases slightly above this
average and group plans will experience a lower average increase.
Effective Date
Many
of the covered preventive services include a recommendation as to frequency,
method, treatment or setting for the provision of that service. For instance,
the USPSTF recommends a one-time screening for abdominal aortic aneurysms for
men of certain ages who have ever smoked. A plan may limit coverage of
preventive services to correspond to these limitations. For preventive services with USPSTF recommendations in force prior
to September 23, 2009, a plan must provide coverage for plan years that begin
on or after September 23, 2010. New
recommendations made after September 23, 2009 must be implemented for plan
years that begin one year after the date the recommendation or guideline is
issued.
Healthcare.gov includes a "date in effect" column next to each preventive service
recommendation so plan sponsors will only need to visit the site once per year
to determine which services must be covered with no cost-sharing.
The McCart Group will continue to update you
on the regulations as they are released. |