Filed under: National Healthcare | Tags: Employer Requirment, National Healthcare, SBC, Summary of Benefits & Coverage
The Affordable Care Act (ACA) requires all group health plans, including grandfathered plans and self-insured plans, to provide participants and beneficiaries a summary of benefits and coverage (SBC). The effective date for compliance with the SBC requirements under the ACA was delayed pending further guidance (proposed regulations had been issued in August 2011). The Departments of Labor, Treasury and Health and Human Services (the Departments) issued final rules regarding these provisions which will take effect beginning in September 2012.
Who Must Provide an SBC?
For fully-insured plans, both the carrier and the plan administrator (typically the employer) are responsible for providing the SBC to participants and beneficiaries. The final regulations provide that as long as either one of them provides a complete SBC in a timely manner, the requirement will be deemed satisfied for the other party. Employers should reach out to their carriers to discuss who will take on this responsibility. For self-insured plans, the plan administrator is responsible to provide the SBC and employers should contact their third-party administrator for assistance. The final regulations clarify that a single SBC may be provided to a participant and any beneficiaries at the participant’s last known address. If a beneficiary’s last known address is different than the participant’s, a separate SBC must be furnished to such address.
What is Required to be in the SBC?
- The following information must be included in the SBC:
- Uniform definition of standard insurance terms and medical terms;
- Description of the coverage, including cost sharing for each category of benefits;
- Exceptions, reductions and limitations of coverage;
- Cost sharing provisions including deductibles, coinsurance and copay obligations;
- Renewability and continuation of coverage provisions;
- Coverage examples;
- Statement that the SBC is only a summary and that the plan document, policy or certificate of insurance should be consulted;
- Contact information for questions and to obtain the plan document, policy or certificate of insurance;
- Internet address to obtain a list of network providers;
- If the plan has a prescription drug formulary, an internet address to obtain information on prescription drug coverage; and
- Internet address to review the uniform glossary, and a statement that paper copies are available, as well as contact information for how to get them.
Helpful Links
Compliance Guide: www.dol.gov/ebsa/pdf/SBCguidance.pdf
Summary of Benefits and Coverage Template: www.dol.gov/ebsa/pdf/SBCtemplate.pdf
Instructions for Completing the SBC – Group Plans: www.dol.gov/ebsa/pdf/SBCInstructionsGroup.pdf
Uniform Glossary of Coverage and Medical Terms: www.dol.gov/ebsa/pdf/SBCUniformGlossary.pdf
Filed under: HR
We all know how hard it is in this economy to keep the good employees we have and attract the good ones we want. How much do the “bells and whistles” we offer as an employer weigh in on the choice employees make to stay with us or move on; or new employees to find a new home within our firm?
Kyle Lagunas, an HR Market Analyst at Software Advice, takes a look at just this, in his blog “Software Advice”. Sometimes it is just the “little things” that make the big difference.
Click here to read more.
Filed under: National Healthcare
The Wage Theft Prevention Act is a new Act that went into effect April of 2011. The Act gives greater protection to workers, and makes changes in the way they are notified of their pay rates and receive wage statements. Pursuant to the Act, beginning in 2012, all New York employers must provide an annual pay notice to all employees (exempt and non-exempt) who work in New York (they must also do so upon hire). The annual notice must be provided to employees between January 1st and February 1st of each year. The notice must include the following information:
• Dates of work covered;
• Employer’s address and phone number;
• The rate of pay and the manner in which it is paid (hourly, salary, commission, etc.)
• Gross wages; net wages;
• Deductions;
• Allowances against minimum wage; and
• For non-exempt employees, the regular rate, overtime rate, and the number of regular and overtime hours worked.
The notices may be provided to employees electronically, as long as employees can acknowledge receipt and print the notice. A copy of the notice must be maintained by employers for six years.
Under the law, employers can be assessed a penalty of $50 per week per employee if proper notice is not given (employees have a separate cause of action up to $2,500).
The New York State Department of Labor provides FAQs that contain further information and can be found at:
http://www.labor.ny.gov/workerprotection/laborstandards/PDFs/wage-theft-prevention-act-faq.pdf
Filed under: Exciting News
In case you missed it! Here is the link to the video for ringing the NYSE Opening Bell this morning.
I can honestly say this was the highlight of my professional carrier, so far…. But how can you top this!?!?
Filed under: Exciting News
Tune in on December 27th 9:25 AM to watch the President of Combs & Company help ring the New York Stock Exchange Opening Bell!
You can tune in live online at 9:29am EST via the provided link below or watch it live on television through CNBC, or Fox Business Network.
http://www.nyse.com/attachment/liveflashbell.htm
The honor of ringing the opening bell comes in celebration of the Women in Insurance and Financial Services (WIFS) 75th Anniversary. Susan is currently on the National & Local Board of Directors of WIFS.
Filed under: Motivational
My father always told me there are three major aspects to your life – you have the person you are with, the place where you live, and the thing you do for a living. If you’re happy with 3 out of 3 then you are living a golden life; but on any given day, if you can be happy in at least 2 of those aspects, you’re doing just fine. But if you’re happy with only one or none at all, the get off your butt and do something about it. Surround yourself with supportive people who “get” you; to whom you don’t have to explain yourself. Live in a place that excites you and that cultivates who you are and who you want to be. Choose to do something you love because invariably you’ll do it well.
My friend Ron Williams has a saying, “If you are not a wind in my sail, then you are an anchor on my tail.” I have a tremendous husband (my word not his), a great family, and fantastic friends. I have them all because I choose to have them in my life (and yes, that goes for my family). I live in a city that doesn’t bullshit me; it gives me just as good as it takes from me. And I get to decide on the clients I want to work with. My business theory is fairly simple – if I wouldn’t Friend someone on Facebook, then I don’t want them as a client. That’s how I lead my life.
No matter what your aspirations are in life be the kind of person that when your feet hit the floor in the morning, the devil says, “Oh crap, they’re up.”
Filed under: Blue Cross
As you may have heard Blue Cross will be making some drastic changes to its health insurance portfolio starting April 1, 2012. Currently Blue Cross offers more than 30 health plan options to small businesses (2-50 employees), but as of April 1st they are eliminating most of their portfolio and reducing your options to 4 meager plans.
This is a forced migration to one of the four plans, regardless of when your renewal date occurs. For example, if your renewal is January 1, 2012, you can renew on your current plan at 1st quarter rates, but come April 1st, you will have to choose one of the four plans Blue Cross is making available and do so at 2nd quarter rates.
Blue Cross has provided us with a preview of the four plans that will be available for Small Businesses. If you would like to see the plan structures, please email us at info@combsandco.com and we will send you a copy.
This is a confusing time in health insurance, and we don’t anticipate it will clear up anytime soon.
Filed under: P&C Insurance
Have you ever wondered when it comes to your insurance, who actually is covered in regards to your company structure? The wait is over, take a look at this user friendly gride we created for our clients!
Who Is An Insured
|
Designation In Declarations |
Who Are Insureds |
Restrictions |
|
Individual |
Named Insured
Named Insured’s Spouse |
Only in connection |
|
Partnership or |
Named Insured
Named Insured’s members and their spouses Named Insured’s partners and their spouses |
Members, partners |
|
LLC |
Named Insured
Members Managers |
Members are |
|
Organizations other |
Named Insured
Executive Officers and Directors Stockholders |
Executive officers |
|
Trust |
Named Insured
Trustees |
Trustees are |
Filed under: National Healthcare
The essential benefits package will become the standard for health coverage and will be used as the basis for establishing the different benefit levels of plans that will be offered in the health insurance exchange. In addition, all new health plans that are sold to individuals will have to cover, at a minimum, all of the health care services in the essential benefits package. In 2014, all Small Group (1 to 100 Employees) will include these essential benefits as well. This will help ensure that every health plan provides the quality of coverage and financial protections necessary to safeguard families from the devastating financial effects of illness.
Right now, the Department of Health and Human Services (HHS) has come out with an estimation of what these benefits will be. They are as follows:
- Ambulatory Patient Care
- Emergency Room Services
- Hospitalization
- Maternity & Newborn Coverage
- Mental Health & Substance Abuse
- Prescription Benefit
- Rehab
- Prevention & Wellness
- Pediatrics Including Oral & Vision
There may be some more tweaks to this, but this is a solid estimation that you can pretty much take to the bank!
Filed under: National Healthcare
To explain this is layman’s terms we need to start off with a couple of definitions:
Exchange: is a set of state regulated and standardized health care plans, from which individuals may purchase health insurance.
Full Time Employee: 30 or more hours worked during the week
Full Time Equivalent (FTE): a calculation where you add up all the employees who work 30 hours or more per week, and then give partial credit to those employees who work less than 30 hours per week.
For example, let’s look at a company that has 70 actual people working for it:
35 Employees work 30 hours or more per week = 35 Employees
20 Employees work 20 hours per week = 13.33 Employees ((20 x 20) / 30)
10 Employees work 15 hours per week = 5 Employees ((10 x15) / 30)
5 Employees work 10 hours per week = 1.66 Employees ((5×10) / 30)
FTE count is 55 Employees
Household Income: Total taxable Income recorded per household (not per individual)
What you should know:
Point 1:
In 2014, if you have 50 or more employees you are obligated to offer them Group Health Coverage or potentially face a fine. If you decide not to, and 1 employee enters the Exchange to get health coverage, you not only get hit with a $2,000 fine for that employee, you are hit with a fine for ALL your calculated FTE employees. However, the legislation exempts the first 30 employees from the fine calculation (i.e., if the employer has 55 FTE employees as in the example above, the employer pays the fine for 25 employees).
In our example above, for that one employee going to the Exchange, the employer would be hit with a fine of $50,000 (Total Employees 55 – 30 exempt = 25 x $2,000) for that year alone. This is a steep penalty, but if you weigh it against the potential cost of health insurance, it may be worth paying the fine.
Point 2:
In 2014, if an employer offers Group Health Coverage, it must be deemed Affordable. If an employee’s contribution to an employer-sponsored health plan is greater than 9.5% of that employee’s HOUSEHOLD income, it is deemed Unaffordable. If this employee applies to and is accepted by the Exchange, the employer will be fined $3,000 for that employee, and any other employee that enters the Exchange under similar circumstances.
There are numerous issues with this setup, but two of the most obvious are:
- As an employer, you are not allowed to ask an employee what their household income is.
- By 2014, non-discriminiation laws will be in effect, so you must treat ALL employees the same in regards to contributions. This is either done as a percentage of the premium or flat dollar amount; you are unable to do it as a percentage of income. For example, the employer contributes $300 per month towards the premium or the employer contributes 75% of the cost of the premium on a monthly basis.
What this means for you as an employer?
- Some employers may decide to take the penalty for not offering coverage since in our example a $50,000 fine is still far less than health insurance premiums for 55 FTEs annually. This will result in even more uninsured just due to cost.
- Even if you do your homework, know that there are elements to this law that may put you out of compliance.
What brokers are trying to do?
We are working with our lobbying group, National Association of Health Underwriters (NAHU,www.nahu.org) to have this changed so that employers are allowed to create a Safe Harbor, if you have looked at the lowest wage employee’s contribution when you set up your contributions. Also, we are advocating for a “Last Look” by employers so they can correct this immediately to go into compliance.
What you can do?
Call your Congressman. Let them know you have some concerns and that some of these fines would be detrimental to your company.
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