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Banyan Consulting LLC has been providing us with beneficial information about different aspects of the Health Care Reform and how it affects us. Over the next months and years, employers will be faced with numerous changes, many of which require regulatory clarification. Banyan will continue to keep us up to date and on target with decisions that affect our plans. 

To view this article in PDF format, click here.

The following information is provided by Banyan Consulting LLC:

What You Need to Know Now About:  Lifetime and Annual Limits

The Patient Protection and Affordable Care Act (“Affordable Care Act”) signed into law on 03/23/2010 includes changes to any limits on the benefit amount payable on a per participant basis by an employer-sponsored group health plan.  These provisions take effect on the first day of the first plan year following 9/23/2010.  Lifetime limits on a per participant basis will be prohibited.  Annual limits on a per participant basis will still be permitted on a restricted basis until 2014 when those, too, are prohibited.

1. Does the health care reform provision on Lifetime and Annual Limits apply to “grandfathered” health plans?

Yes, this provision applies to both grandfathered and non-grandfathered health plans.  Also, your plan’s funding arrangement, fully-insured or self-funded, does not impact your requirement to comply.

2. Currently, my employer-sponsored group health plan has a $1,000,000 lifetime maximum.  What do I need to do in order to be compliant?

Effective with the first day of your next new plan year after 9/23/2010, you must remove the $1,000,000 lifetime maximum and replace it with an unlimited lifetime maximum.

You will also need to determine if there has been any plan participants who had reached the $1,000,000 lifetime maximum and were dropped by the plan.  You will need to contact them, alert them of the new unlimited lifetime maximum, and offer them the opportunity to re-enroll into the health plan effective on the first day of your next new plan year after 9/23/2010.

3. Do the lifetime and annual maximum changes apply only to in-network providers?

The Interim Final Regulations issued by the Department of Labor on 6/23/2010 are not entirely clear on this subject; however, the interpretation of the regulations is that there is no distinction for network participation.  The lifetime and annual limits are on a per participant basis and provider network affiliation does not factor into the reform provision. (continue reading…)

Banyan Administrators have been providing us with beneficial information about different aspects of the Health Care Reform and how it affects us. Over the next months and years, employers will be faced with numerous changes, many of which require regulatory clarification. Banyan will continue to keep us up to date and on target with decisions that affect our plans. 

To view this article in PDF format, click here.

The following information is provided by Banyan Administrators:

Another component of the Health Care Reform Act signed into law on 3/23/2010 is that beginning with the 2011 tax year, employers must report the aggregate cost of applicable employer-sponsored health insurance coverage on employees W-2 forms.  General information about this requirement has been provided, however, the Department of Labor (DOL) has not yet issued Interim Final Rules on this provision of the Health Care Reform Act.

1. When does an employer have to be ready to be in compliance with this new reporting requirement?

Employers must be prepared to accurately report this information on an employee’s 2011 W-2 form as early as February, 2011.  Although employers will be sending most of the 2011 W-2 forms to the employees in January, 2012, if an employee terminates employment in 2011, they do have the right to request an early 2011 W-2 form.  Employers must be prepared for this possibility. (continue reading…)

Banyan Consulting LLC has been providing us with beneficial information about different aspects of the Health Care Reform and how it affects us. Over the next months and years, employers will be faced with numerous changes, many of which require regulatory clarification. Banyan will continue to keep us up to date and on target with decisions that affect our plans. 

To view this article in PDF format, click here.

The following information is provided by Banyan Consulting LLC:

One component of the Health Care Reform Act signed into law on 3/23/2010 requires minimum coverage, without employee cost-sharing, for services rated A or B by the US Preventive Services Task Force.  Beginning with the first day of the first plan year beginning on or after 9/23/2010, plans can no longer require a copay or apply a deductible or coinsurance to these services.  On 7/14/2010, the Department of Health & Human Services (HHS) released the list of A and B services determined by the US Preventive Services Task Force.

1.  Does this health care reform provision apply to “grandfathered” plans?

No, grandfathered plans do not need to comply with this provision.  If, in the future, your health plan loses its grandfathered status, this reform will apply to your plan.

2.  What are the A and B rated preventive services?

The A and B rated preventive services are segmented into 3 categories which are:

•  Adult Covered Preventive Services
•  Women (including Pregnant Women) Covered Preventive Services
•  Children Covered Preventive Services

There is still some debate on additional services for women that, most likely, will not be resolved until August, 2011.  There is lobbying from organizations such as Planned Parenthood, for example, who want birth control to be included in the preventive services category.  More information is sure to follow. (continue reading…)

 Banyan Consulting LLC has been providing us with beneficial information about different aspects of the Health Care Reform and how it affects us. Over the next months and years, employers will be faced with numerous changes, many of which require regulatory clarification. Banyan will continue to keep us up to date and on target with decisions that affect our plans. 

The following information is provided by Banyan Consulting LLC:

With the passage of the Patient Protection and Affordable Care Act on March 23, 2010, effective January 1, 2011 over-the-counter (OTC) medicine will no longer be eligible for reimbursement from a Flexible Spending Account (FSA), Health Reimbursement Account (HRA) or Health Savings Account (HSA) unless accompanied by a prescription or medical necessity statement from a medical provider.  The new regulation only applies to OTC medicine so many OTC supplies that are, currently, eligible for reimbursement through an FSA, HRA or HSA will not be affected. To read more, click here.

Banyan Consulting LLC has been providing us with beneficial information about different aspects of the Health Care Reform and how it affects us. Over the next months and years, employers will be faced with numerous changes, many of which require regulatory clarification. Banyan will continue to keep us up to date and on target with decisions that affect our plans. 

The following information is provided by Banyan Consulting LLC:

Under the Health Care Reform law, existing, or “grandfathered” health plans are exempt from several consumer protections in the law that are going into effect for new plan years beginning after 9/23/2010.  Congress included this grandfather clause in the bill to give employers and insurers time to transition to the new law.  On 6/14/2010, The Department of Health and Human Services (HHS) issued guidance on what flexibilities exist for employers to maintain their grandfathered status. Click here  to read more regarding the Grandfather Clause.