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Presenter:
Si Nahra, Ph.D., President
Nate Wallace, Policy and Data Analyst
June 13, 2013
Affordable Care Act (ACA)
Employer Mandate
Calculations Explained
222
About Health Decisions, Inc.
Pioneering Specialists inPioneering Specialists in
Group Health CareGroup Health Care
Post-Payment AdministrationPost-Payment Administration
For Over 25 YearsFor Over 25 Years
RespectRespect for Existing Proceduresfor Existing Procedures
EmphasisEmphasis on Customizationon Customization
FocusFocus on Solutionson Solutions
Customer Philosophy
Copyright Health Decisions, Inc.
6/2013
Today’s Session
Second in a three-part series on Affordable Care Act
(ACA) compliance for self-funded plans.
Today’s focus is on calculations to be performed as part
of ACA compliance.
Copyright Health Decisions, Inc.
6/2013
3
Employer Mandate Calculations
• Minimum Value Test
• Affordability Test
• FTE Tests
– Large Employer Status
– Eligibility Test
– Offer Test
• Member Counts
• OOP (Out-of-Pocket) Accumulation
Copyright Health Decisions, Inc.
6/2013
4
What do you need?
• Plan Documentation and Information
• Payroll Data
• Enrollment Rosters
• Claims Data (medical and Rx)
All available to every self-funded plan.
Copyright Health Decisions, Inc.
6/2013
5
When do tests occur?
Test Initial Annually Adds/Deletes
Life Events
Monthly
Minimum Value  
Affordability   
FTE
- Large Employer  
- Eligibility Test   
- Offer Test   
Member Counts  
OOP Accumulator   
Copyright Health Decisions, Inc.
6/2013
6
Minimum Value
• Plans must cover at least 60% of total
allowed costs of benefits
• What do you need?
Plan Documents
MV Calculator
• Department of Health and Human Services
(HHS) and IRS released calculator
http://www.cms.gov/CCIIO/Resources/Regulations-and-Guidance/index.html
Copyright Health Decisions, Inc.
6/2013
7
Minimum Value Calculator - Highlights
HSA/HRA
Amount ($)
$2000 Annual Contribution
Tier 1 (In-Network) Tier 2 (Out-of-Network)
Utilization (%) 70% 30%
Medical Drug Medical Drug
Deductible ($) $600 $400 $1200 $800
Coinsurance (%) 80% 90% 70% 60%
OOP Max ($) $4000 $2000 $5000 $3000
Copyright Health Decisions, Inc.
6/2013
8
Affordability Test
• Employees premiums cannot exceed 9.5% of
their household income
• What do you need?
Plan Documents
Payroll data
Possibly survey of family income
• IRS’s W-2 Safe Harbor
Copyright Health Decisions, Inc.
6/2013
9
Affordability Test
Employee
Income
Premiums Paid by Employee
Copyright Health Decisions, Inc.
6/2013
10
FTE Tests
Large Employer
50+ FTEs
•What do you need?
Payroll data
•Full-Time Equivalent
100 variable hour employees = 50 FTEs
Copyright Health Decisions, Inc.
6/2013
11
FTE Tests
Eligibility Test
– Average of 30+ hours of service per week
•What do you need?
Payroll data
Order Period Length
(min.)
Length
(max.)
1 “Look-Back” 3 months 12 months
2 (Optional) Administrative 0 days 90 days
3 Stability 6 months 12 months
Copyright Health Decisions, Inc.
6/2013
12
ACA Complete Cycle
“Look-Back” Period
Admin.
Period
“Look-Back” Period
Admin.
Period
Stability PeriodStability Period
OngoingOngoing
Copyright Health Decisions, Inc.
6/2013
13
FTE Complex Categories
• Seasonal Workers
• Temp Workers
• Commission based Workers
• Leave of Absence
• New Employees
Copyright Health Decisions, Inc.
6/2013
14
Offer Test
Maybe not a “test” but something to be documented.
Need to show coverage offer made to all eligible people.
Required Communications to Eligible employees using
defined terms and forms.
•Part of any or all of these events
– Administrative Period
– Open Enrollment Communications
– Employee Communication Outside Open Enrollment
Copyright Health Decisions, Inc.
6/2013
15
Member Counts
2 applicable taxes based on member counts
Comparative Effectiveness Research Fee (CERF)
$1PMPY due in July $2 next year
Reinsurance Assessment
$63 PMPY 2014, $45 2015, $30 2016
•What do you need?
– Enrollment Roster(s) with dependents VERIFIED
(non-verified adds 4%-12% ineligible dependents)
– Checkbook
Copyright Health Decisions, Inc.
6/2013
16
OOP Accumulation
• New definitions
• New rules
• Requires
– Claims data
– Medical and Rx
• Requires integration of cost sharing amounts
across plans.
Copyright Health Decisions, Inc.
6/2013
17
ObamaCare Compliance
Next Webinar: June 27th
“Obamacare” Compliance: How It
Helps Self-funded Plans
Click to register
Copyright Health Decisions, Inc.
6/2013
18
191919
Past Webinars Available
Recordings of past webinars are available upon request, including:
• May 2013 – Pay or Play: A Bigger Challenge for TPAs than for Plans
• April 2013 - The Most Overlooked Part of Health Reform: Enrollee Communications
• March 2013 – Why Cost Sharing is not Working
• February 2013 – Loss of Fiduciary Control
• January 2013 – Top 10 Do’s and Don'ts of Data Warehousing
• December 2012 – Union Trusts: Health Reforms Most Overlooked Winner?
• November 2012 – Year-end Renewal and Bidding: Opportunities for Control and Savings
• October 2012 – The 5 Most Important Things an Effective Dependent Audit Should Include
• September 2012 – Old Question, New Twist: Is Self-funding Right for Your Group Health Plan?
• August 2012 – Are You Ready to Manage Your Health Plan Costs?
• June 2012 - Group Health Brokers’ Future: Disintermediation or Re-intermediation
• May 2012 – Five Levers of Management Control
• April 2012 – How the AMA Can Help You with Plan Oversight
For more information, please visit www.healthdecisions.com
Copyright Health Decisions, Inc.
6/2013
202020
For More Information
Contact
si@healthdecisions.com
734-451-2230
Connect with me on LinkedIn
Add me to your circles on Google+
Like us on FaceBook
Follow us on Twitter
Copyright Health Decisions, Inc.
6/2013

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Health Decisions Webinar: Employer Mandate Calculations Explained

  • 1. Presenter: Si Nahra, Ph.D., President Nate Wallace, Policy and Data Analyst June 13, 2013 Affordable Care Act (ACA) Employer Mandate Calculations Explained
  • 2. 222 About Health Decisions, Inc. Pioneering Specialists inPioneering Specialists in Group Health CareGroup Health Care Post-Payment AdministrationPost-Payment Administration For Over 25 YearsFor Over 25 Years RespectRespect for Existing Proceduresfor Existing Procedures EmphasisEmphasis on Customizationon Customization FocusFocus on Solutionson Solutions Customer Philosophy Copyright Health Decisions, Inc. 6/2013
  • 3. Today’s Session Second in a three-part series on Affordable Care Act (ACA) compliance for self-funded plans. Today’s focus is on calculations to be performed as part of ACA compliance. Copyright Health Decisions, Inc. 6/2013 3
  • 4. Employer Mandate Calculations • Minimum Value Test • Affordability Test • FTE Tests – Large Employer Status – Eligibility Test – Offer Test • Member Counts • OOP (Out-of-Pocket) Accumulation Copyright Health Decisions, Inc. 6/2013 4
  • 5. What do you need? • Plan Documentation and Information • Payroll Data • Enrollment Rosters • Claims Data (medical and Rx) All available to every self-funded plan. Copyright Health Decisions, Inc. 6/2013 5
  • 6. When do tests occur? Test Initial Annually Adds/Deletes Life Events Monthly Minimum Value   Affordability    FTE - Large Employer   - Eligibility Test    - Offer Test    Member Counts   OOP Accumulator    Copyright Health Decisions, Inc. 6/2013 6
  • 7. Minimum Value • Plans must cover at least 60% of total allowed costs of benefits • What do you need? Plan Documents MV Calculator • Department of Health and Human Services (HHS) and IRS released calculator http://www.cms.gov/CCIIO/Resources/Regulations-and-Guidance/index.html Copyright Health Decisions, Inc. 6/2013 7
  • 8. Minimum Value Calculator - Highlights HSA/HRA Amount ($) $2000 Annual Contribution Tier 1 (In-Network) Tier 2 (Out-of-Network) Utilization (%) 70% 30% Medical Drug Medical Drug Deductible ($) $600 $400 $1200 $800 Coinsurance (%) 80% 90% 70% 60% OOP Max ($) $4000 $2000 $5000 $3000 Copyright Health Decisions, Inc. 6/2013 8
  • 9. Affordability Test • Employees premiums cannot exceed 9.5% of their household income • What do you need? Plan Documents Payroll data Possibly survey of family income • IRS’s W-2 Safe Harbor Copyright Health Decisions, Inc. 6/2013 9
  • 10. Affordability Test Employee Income Premiums Paid by Employee Copyright Health Decisions, Inc. 6/2013 10
  • 11. FTE Tests Large Employer 50+ FTEs •What do you need? Payroll data •Full-Time Equivalent 100 variable hour employees = 50 FTEs Copyright Health Decisions, Inc. 6/2013 11
  • 12. FTE Tests Eligibility Test – Average of 30+ hours of service per week •What do you need? Payroll data Order Period Length (min.) Length (max.) 1 “Look-Back” 3 months 12 months 2 (Optional) Administrative 0 days 90 days 3 Stability 6 months 12 months Copyright Health Decisions, Inc. 6/2013 12
  • 13. ACA Complete Cycle “Look-Back” Period Admin. Period “Look-Back” Period Admin. Period Stability PeriodStability Period OngoingOngoing Copyright Health Decisions, Inc. 6/2013 13
  • 14. FTE Complex Categories • Seasonal Workers • Temp Workers • Commission based Workers • Leave of Absence • New Employees Copyright Health Decisions, Inc. 6/2013 14
  • 15. Offer Test Maybe not a “test” but something to be documented. Need to show coverage offer made to all eligible people. Required Communications to Eligible employees using defined terms and forms. •Part of any or all of these events – Administrative Period – Open Enrollment Communications – Employee Communication Outside Open Enrollment Copyright Health Decisions, Inc. 6/2013 15
  • 16. Member Counts 2 applicable taxes based on member counts Comparative Effectiveness Research Fee (CERF) $1PMPY due in July $2 next year Reinsurance Assessment $63 PMPY 2014, $45 2015, $30 2016 •What do you need? – Enrollment Roster(s) with dependents VERIFIED (non-verified adds 4%-12% ineligible dependents) – Checkbook Copyright Health Decisions, Inc. 6/2013 16
  • 17. OOP Accumulation • New definitions • New rules • Requires – Claims data – Medical and Rx • Requires integration of cost sharing amounts across plans. Copyright Health Decisions, Inc. 6/2013 17
  • 18. ObamaCare Compliance Next Webinar: June 27th “Obamacare” Compliance: How It Helps Self-funded Plans Click to register Copyright Health Decisions, Inc. 6/2013 18
  • 19. 191919 Past Webinars Available Recordings of past webinars are available upon request, including: • May 2013 – Pay or Play: A Bigger Challenge for TPAs than for Plans • April 2013 - The Most Overlooked Part of Health Reform: Enrollee Communications • March 2013 – Why Cost Sharing is not Working • February 2013 – Loss of Fiduciary Control • January 2013 – Top 10 Do’s and Don'ts of Data Warehousing • December 2012 – Union Trusts: Health Reforms Most Overlooked Winner? • November 2012 – Year-end Renewal and Bidding: Opportunities for Control and Savings • October 2012 – The 5 Most Important Things an Effective Dependent Audit Should Include • September 2012 – Old Question, New Twist: Is Self-funding Right for Your Group Health Plan? • August 2012 – Are You Ready to Manage Your Health Plan Costs? • June 2012 - Group Health Brokers’ Future: Disintermediation or Re-intermediation • May 2012 – Five Levers of Management Control • April 2012 – How the AMA Can Help You with Plan Oversight For more information, please visit www.healthdecisions.com Copyright Health Decisions, Inc. 6/2013
  • 20. 202020 For More Information Contact si@healthdecisions.com 734-451-2230 Connect with me on LinkedIn Add me to your circles on Google+ Like us on FaceBook Follow us on Twitter Copyright Health Decisions, Inc. 6/2013

Notes de l'éditeur

  1. We want to pose initial questions to participants at this point: Are you a self-funded plan (choose one) __fiduciary __manager __advisor __administrator What is the approximate number of active employees in the self-funded plan you represent? __under 100 __100-1000 __1000 to 5000 __over 5000 What is the approximate number of retirees in the self-funded plan you represent? __ none __under 100 __100-1000 __1000 to 5000 __over 5000