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Pre-Deductible Telehealth Coverage Extension Included in 2023 Spending Bill

January 03 - Posted at 2:52 PM Tagged: , , , ,

Employers will have the option to provide pre-deductible coverage of telehealth services for people with high-deductible health plans for another two years.

The $1.7 trillion omnibus spending bill signed into law by President Joe Biden Dec. 29—which contains a number of other important provisions affecting employers, including the Secure 2.0 retirement overhaul and pregnancy accommodations—includes a provision extending the telehealth relief in the 2020 Coronavirus Aid, Relief and Economic Security (CARES) Act.

Significantly for employers, the provision allows health savings account (HSA)-qualifying high-deductible health plans (HDHPs) to cover telehealth and other remote-care services on a pre-deductible basis. Additionally, an otherwise HSA-eligible individual can receive pre-deductible coverage for telehealth and other remote-care services from a stand-alone vendor outside of the HDHP. In both cases, the pre-deductible telehealth coverage won’t hinder an individual’s eligibility to make or receive HSA contributions. Many employer groups and stakeholders have said that the waiver improves health access, notably for some employees who may have avoided telehealth because of out-of-pocket expenses.

SHRM has been advocating for the continuation of pre-deductible telehealth coverage, arguing that improved access to telehealth allows employees to access more health care options—including mental health services—at their convenience.

“Pre-deductible coverage helps employees because it allows insurance providers to cover telehealth services without requiring a co-pay or deductible upfront,” said Emily Dickens, SHRM chief of staff, head of public affairs and corporate secretary. “Employers need the flexibility to design benefit plans that improve employees’ well-being and help retain top talent. I am grateful to our members for engaging with lawmakers from across the nation to secure this extension.”

The CARES Act allowed HSA-eligible health plans to provide pre-deductible coverage for telehealth services, but only through 2021. Normal cost-sharing was still allowed for telehealth visits, such as through co-pays that the plan may require after the deductible is paid. It was then renewed in the 2022 Consolidated Appropriations Act for April 1 through Dec. 31, 2022.

The omnibus bill also extends Medicare telehealth provisions for another two years, including delaying in-person screening requirements for Medicare telehealth mental health services and allowing providers to provide acute hospital-level care at home.

Still, the extensions don’t permanently extend telehealth relief—something many health and policy experts advocate for. Without a further extension, the telehealth relief will expire Dec. 31, 2024, for calendar-year plans. Some groups expect Congress might make these changes permanent, although some lawmakers are concerned with telehealth’s potential for higher costs and increased fraud.

 

IRS Publishes 2018 Indexed Figures

October 24 - Posted at 10:34 AM Tagged: , , , , , , , , , ,
The IRS recently published indexed figures for 2018 including changes to the following:

Maximum H.S.A. Annual Contribution Limits-
  • 2018- $3450 Self / $6900 Family 
  • $2017- $3400 Self / $6750 Family
The H.S.A. catch up limit for individual age 55 and over will remain at $1000.

Medical Plan Maximum Out of Pocket Limits-
  • 2018- $7350 self / $14,700 Family
  • 2017- $7150 self / $14,300 Family
The 2018 FSA annual contribution limit was increased from $2600 to $2650. Dependent Day Care Assistance contribution limit  remains at $5000 if single head of household or married and filing jointly ($2500 if married and filing separately). 

The American Health Care Act Passes the House of Representatives

May 05 - Posted at 4:18 PM Tagged: , , , , , , , , , , , , ,

Yesterday (May 4, 2017) , the House of Representatives narrowly passed the American Health Care Act of 2017 (AHCA), which contains major parts that would repeal and replace the Affordable Care Act (commonly referred to as Obamacare or ACA).  The next obstacle the bill faces is making it through the Senate, which proves to be a formidable challenge.


The nonpartisan Congressional Budget Office has not had time yet to analyze the current version of the bill, but this is expected next week. The bill must now pass the Senate and could get pushed back to the House if it sees changes in the upper chamber.

In the meantime, here are some highlights we know about the bill based on how it is written today and how it would work:


  • The AHCA bill would eliminate the requirement that people buy health insurance (known as the individual mandate).  
  • The bill would eliminate penalties for large employers (50+ employees) that do not provide insurance to their employees.
  • The bill would impose a penalty for people who don’t maintain continuous health insurance. The AHCA would create a penalty for people who have a gap in their health insurance of more than 63 days.  People buying insurance in the individual market who have a gap of 63 days or longer could be charged a “late enrollment penalty” by the carriers that could be up to 30% of the premium price.
  • The bill would end Medicaid expansion.
  • The bill would cut Medicaid spending.
  • The bill would change how subsidies to buy health insurance are allocated.
  • The bill keeps requirements that insurers must sell coverage to everybody.
  • The bill would allow states to change which benefits insurers are required to provide to people who buy plans on their own. The AHCA would allow states to waive the current requirements of “Essential Health Benefits” (aka EHB) under Obamacare that are imposed on plans or allow states to set up their own list of EHBs that insurers must cover in the individual market.
  • The bill would allow insurers to charge older people more than under the current law. The ACA limits insurers to charging older customer to 3 times a much as younger customers in the individual market. The AHCA expands that ratio to allow insurers to charge older customers 5 times as much as younger customers (it was 10 times prior to Obamacare).
  • The bill would allow states to let insurers charge older people even more. Under the AHCA, states could seek a waiver from the federal government regarding the age ratios which would let them set their own ratios above the 5 times ratio set by the government.
  • The bill would allow states to end requirements that insurers cover pre-existing conditions.
  • The bill could lead to states setting up special insurance programs for high cost patients. The main requirements for a waiver on pre-existing conditions is that states must set up some kind of program to cover the most costly customers (aka high risk pools).
  • The bill could impact the benefits covered by employer sponsored insurance.
  • The bill would keep the insurance exchanges in place.
  • The bill would allow kids to stay on their parent’s plan until age 26.
  • The bill would repeal multiple taxes that helped fund the ACA.
  • The bill would cut federal spending by hundreds of billions of dollars.
  • The bill would return over the counter medications to the list of qualified medical expenses for the 2017 tax year.
  • The bill would reduce the tax penalty on health savings accounts from 20% to 10% for distributions that are not used for qualified expenses.
  • The bill would repeal the limitation of $2500 on health FSA contributions.
  • The bill would increase H.S.A. contributions for a year to equal the maximum on the sum of the annual deductible and out of pocket expenses.
  • The bill would allow both spouses to make catch up contributions in one H.S.A.


We will continue to keep you up to date on the bill as it progress through legislation.

Proposed Changes for the Summary of Benefits and Coverage (SBC)

January 16 - Posted at 6:35 PM Tagged: , , , , , , , , , , , , , , , ,

On December 22, 2014, the Departments of Health and Human Services (HHS) issued proposed regulations for changes to the Summary of Benefits and Coverage (SBC).

 

The proposed regulations clarify when and how a plan administrator or insurer must provide an SBC, shortens the SBC template, adds a third cost example, and revises the uniform glossary. The proposed regulations provide new information and also incorporate several FAQs that have been issued since the final SBC regulations were issued in 2012.

 

These proposed changes are effective for plan years and open enrollment period beginning on or after September 1, 2015. Comments on the proposed regulations will be accepted until March 2,2015 and are encourages on many of the provisions.

 

New Template

 

The new SBC template eliminates a significant amount of information that the Departments characterized as not being required by law and/or as having been identified by consumer testing as less useful for choosing coverage.

 

The sample completed SBC template for a standard group health plan has been reduced from four double-sided pages to two-and-a-half double-sided pages. Some of the other changes include:

 

  • An additional cost example for a simple foot fracture treated in an emergency room, which will be added to the two current examples. This new example is proposed as a health problem that any individual could experience, while the two current examples- having a baby and managing type 2 diabetes- affect only certain individuals.
  • The coverage example calculator will be authorized for continued use and updated claims and pricing data for the two existing exampled and the third example will be provided.
  • References to annual limits for essential health benefits (EHBs) and preexisting condition exclusions  will be removed.
  • Information regarding minimum essential coverage (MEC) and minimum value (MV) has been revised and must be included in the SBC. This effectively ends a temporary enforcement safe harbor that previously permitted statements about MEC and MV to be included in a cover letter rather than in the SBC.
  • Premium information may be included in an SBC, but it is not required.
  • All SBCs must include an issuer website where the individual policy or group certificate of coverage can be reviewed and obtained. Plan administrators are not required to include a website separate from the issuer website.
  • SBCs for individual policies will be required to disclose whether abortion services are covered or excluded and whether coverage is limited to services for which federal funding is allowed.

 

Glossary Revisions

Revisions to the uniform glossary have also been proposed. The glossary must be available to plan participants upon request. Some definitions have been changed and new medical terms such as claim, screening, referral and specialty drug have been added. Additional terms related to health care reform such as individual responsibility requirement, minimum value and cost-sharing reductions have also been added.

 

Paper vs Electronic Distribution

SBCs may continue to be provided electronically to group plan participants in connection with their online enrollment or online renewal of coverage. SBCs may also be provided electronically to participants who request an SBC online. These individuals must also have the option to receive a paper copy upon request.

 

SBCs for self-insured non-federal government plans may continue to be provided electronically if the plan conforms to either the electronic distribution requirements that apply ERISA plan or the rules that apply to individual health insurance coverage.

 

Types of Plans to Which SBCs Apply

The regulations confirm that SBCs are not required for expatriate health plans, Medicare Advantage plans or plans that qualify as excepted benefits. Excepted benefits include:

 

  • Employee Assistance Plans (EAPs) that meet the requirements to be excepted benefits
  • Health Savings Account (HSAs) because they are not group health plans
  • Dental and vision coverage that meet the requirements to be excepted benefits

 

SBCs are required for:

  • Health Reimbursement Arrangements (HRAs) because they are considered group health plans
  • Health Flexible Spending Accounts (FSAs) if they do not qualify as excepted benefits
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