Humana hosts webinars for small and large employers to offer education on the new requirements of healthcare reform and what you need to do to prepare for changes to your benefit programs.
Watch for upcoming webinars here and register in advance, or view our recently archived webinars on-demand.
Get the latest in Health Reform updates. Add your name to our mailing list.
Learn what is happening around the country on Health Reform. View highlights from coast to coast.
For more detailed information on the provisions already in effect and those upcoming, as well as what Humana is doing to support our customers. See our Healthcare Reform Provisions Timeline.
Below reviews upcoming reform provisions and support documents which affects Small Business, Large Groups and occasionally both.
Small Employer is defined as having 1-99 employees.
Individual and small group plans offered inside/outside the exchange must provide the essential benefits package. The minimum benefit package applies to individual and small group new business in 2014 and non-grandfathered existing business. It includes: Ambulatory patient services, Emergency services, Hospitalization, Maternity and newborn care, Mental health & substance abuse, Prescription drug, Rehabilitative & habilitative services/devices, Lab services, Preventive/wellness, Disease management and Pediatric services including oral & vision care.
States are allowed to merge together individual and small group markets if the state determines it is appropriate.
Rating restrictions go into effect for new individual and fully insured small group plans. Insurance companies cannot base premiums on health status, claims experience or gender. Premiums can only vary by age, geography, family size, or tobacco use (no more than 1.5:1).
Healthcare Reform Benefits Decisions Roadmap: Download PDF (990 Kb)
A guide to understanding employer benefits options
A large employer is defined as one with 99 or more employees.
Employers sponsoring group health plans started paying $1 per participant in 2012. This fee increases in 2013 to $2 per participant. Thereafter the amount will be indexed to national health expenditures. This fee phases out by 2019. Revenue from the fee will fund research to determine the effectiveness of various types of medical treatments.
Large employers will be subjected to expanded 5500 reporting requirements to include information on the health insurance coverage of their employees.
A transitional reinsurance program will be established for the individual market and funded by individual and group health plan assessments (totaling $25 billion between 2014 – 2016). This program will provide payments to plans in the individual market that cover high-risk individuals.
Section 6055 requires health insurers and sponsors of self-insured plans to report on this coverage to the IRS annually. The reporting to both individuals and the IRS for 2015 is due in early 2016. It also requires insurers and self-insured plans to report to their MEC recipients, so the individuals can report that coverage when filing their federal taxes.
The 6055 reporting requirement has two goals. It helps individuals verify that they have MEC for purposes of satisfying the Individual Shared Responsibility requirement. At the same time, it enables the IRS to crosscheck that information with insurers or self-insured plans.
Entities subject to 6055 reporting are health insurance issuers, sponsors of self-insured plans, government sponsored programs, such as Medicaid, and providers of other arrangements designated as MEC, such as high-risk pools.
The final rule states that self-insured employers are responsible for reporting this information to the IRS. Humana will provide reporting to the IRS for fully insured groups. If a self-funded employer needs information on covered members and their coverage dates for a calendar year to meet their part of their reporting obligation, a report of covered individuals can be requested through their Humana representative.
Information required to be reported to the IRS by health insurers and sponsors of self-insured plans who provide minimum essential coverage:
Important Note: While the final rule allows reporting of birthdate if SSN cannot be obtained, it also requires the reporting entity (insurer or self-funded employer) to make two attempts to secure the SSN for reporting purposes. This will require Humana to contact the primary insured to obtain missing social security numbers for them or their dependents for all fully insured groups. Humana plans to start this outreach mid-year in 2015 and provide employers with a courtesy advanced notification. You can help by being proactive now in encouraging employees to provide this information up front at enrollment or open enrollment.
Section 6056 reporting requires employers subject to Employer Shared Responsibility to report to the IRS information about the health coverage they provided to their employees. The IRS will use this information to determine if the employer has to pay any penalties for failing to offer coverage or failing to offer coverage that meets minimum value and is affordable. The reporting to both individuals and the IRS for 2015 is due in early 2016. Even the smaller employer (50-99) will need to report the first year to certify they are exempt from a full report for the first year.
Information required to be furnished to the IRS:
Information reported to the IRS with the use of indicator codes will include:
Employers also have to provide statements to employees regarding their health coverage that mirrors the information reported to the IRS — primarily so employees can use this information to help determine if they are eligible for a premium tax credit for health insurance through the Marketplace.
Additional information for Sponsors self-insured plans
Form 1094-B: Transmittal of Health Coverage Information Returns to the IRS
Form 1095-B: Health Coverage Statement to the Primary Insured
Form 1094-C: Transmittal of Employer-Provided Health Insurance Offer and Coverage Information Return
Form 1095-C: Employer-Provided Health Insurance Offer and Coverage – Employee Statement
For 2014, the out of pocket maximums are the same as the maximum out-of-pocket limits applicable to HSA-compatible high deductible health plans under IRS Code (note that the 2012 maximums are $6,050 for self-only coverage and $12,100 for family coverage). For future years, the 2014 limits are increased by the premium adjustment percentage - the percentage increase in the average per capita premium for health insurance coverage. These limits impact individual, small group and large group new business in 2014 and existing non-grandfathered business.
Also known as "guaranteed issue," with this provision health insurers must accept every individual and employer who applies for coverage.
Exchanges are online marketplaces. Insurance Exchanges will be created, along with Small Business Health Options Program (SHOP) Exchanges. In 2014, individuals and small businesses with up to 100 employees can purchase health insurance on these Exchanges. States can allow large employers to participate beginning in 2017.
Annual limits on essential health benefits are prohibited. However, this does not apply to grandfathered individual plans.
Individual and group health plans can no longer impose pre-existing condition exclusions for any person of any age. This includes children under the age of 19 and does not apply to grandfathered individual plans.
The law permits employers to offer employee rewards of up to 30% of the cost of coverage for participating in a wellness program and meeting certain health-related standards.
PROVISION DELAYED. NOW Effective Jan. 1, 2015: Employers with 50 or more full-time employees or full-time equivalents will pay an assessment if they don’t offer adequate and affordable coverage. For more information, visit Healthcare.gov.
The U.S. Treasury Department released final regulations on Employer Shared Responsibility in February 2014. It will take effect Jan. 1, 2015, for employers with 100 or more full-time or full-time equivalent employees. Employers with between 50 and 99 full-time employees (including full-time equivalents) are exempt from the Shared Responsibility penalty until 2016, if the employer provides an appropriate certification and meets certain conditions.
Beginning in 2015 for employers with 100 or more full-time employees (including full-time equivalent employees) and beginning in 2016 for employers with 50 or more full time employees (including full time equivalent employees) must offer coverage that meets the requirements below to full-time employees (those working 30 hours a week or more) and their dependent children or face potential penalties:
Minimum essential coverage (MEC) is defined by the ACA as an employer-sponsored plan offered in a state (including a self-funded plan) or health coverage provided by the government. However, a plan consisting solely of “excepted benefits” such as stand-alone dental coverage is not MEC. Since you are offering a group health plan through Humana or a self-funded plan for which Humana is the administrator, the MEC requirement is satisfied.
Minimum value: All of Humana’s standard plans meet the minimum value requirement.
Affordability*: There are three safe harbor methods for determining affordability:
*Note: This percentage is for plan years beginning on or after 1/1/2015. It is subject to change annually.
If an employer does not offer minimum essential coverage for any calendar month, and any full-time employee obtains a premium subsidy or cost-sharing reduction through the Federal Marketplace or a state-based exchange, the penalty will be $2,000 per year multiplied by the number of full-time employees for each calendar month of the year, minus the first 80 full-time employees (this number decreases to 30 in 2016).
If an employer offers minimum essential coverage but it doesn’t meet the minimum value or affordability guidelines and any full-time employee obtains a subsidy or cost-sharing reduction through the Federal Marketplace or a state-based exchange, the penalty will be the lessor of $3,000 per each full-time employee certified as eligible to receive a premium tax credit or cost-sharing subsidy or $2,000 per year for each full-time employee, minus the first 80 employees (this number decreases to 30 in 2016). This penalty will be calculated calendar month to calendar month.
For employers with a plan year on a calendar year basis, it is 1/1/15. Whether an employer needs to comply as of 1/1/15 or on its plan year date (for those with non-calendar year plan years), depends on whether it qualifies for transition relief that would enable a delay until the plan year date. For more information, consult the final rule posted here.
The non-discrimination rules that currently apply to self-funded health plans are expanded to group fully insured health plans. Plans cannot base an employee's eligibility or continued eligibility for coverage on hourly or annual salary. Employer-provided insurance may not discriminate between employees. This will prevent employers from providing enhanced insurance benefits based on an employee's length of service. Under the new rules, plans may be subject to penalties of up to $100 per enrollee per day for violating the requirements.
Note: HHS has delayed application of the non-discrimination rules to fully insured health plans until additional regulations or other guidance are issued. The recent guidance makes clear that the Treasury Department will not apply the penalties until additional guidance or rules are issued on the nondiscrimination requirements.
Rising healthcare costs are creating the need for employers to review their health plan offerings. And with healthcare reform, even more changes are on their way. Learn what other employers are saying about how they plan to address these challenges.
In 2012, the Kaiser Family Foundation reported that the average premium for single and family coverage rose by a modest 3% and 4% respectively between 2011 and 2012. Interestingly, the growth in premiums has outpaced increases in inflation (2.3% since 2011 and 28% since 2002).
As reported in the 2012 Deloitte survey of U.S employers:
For employers, the task of managing premium cost-sharing is not simple. And with employees who vary widely in income and health, it gets even harder to predict what's in store. In 2014, for example, employers could be penalized if they have employees whose coverage is subsidized through state insurance Exchanges because these employee's group premiums exceed a percentage of their household income.
And that's just one example of how complex managing healthcare reform can be for your company.
By preparing yourself and your organization with information, you can manage healthcare reform successfully.
According to a Towers Watson survey, some companies are already taking steps to inform and educate themselves on healthcare reform. Here are some steps you can take right away:
The only constant is change.
The best thing you can do to protect your employees from this kind of uncertainty is to stay informed. Keep on top of the latest healthcare reform news at websites such as those from the Kaiser Family Foundation or the George Washington University and the Robert Wood Johnson Foundation
This information is only a high-level summary of certain provisions of the health care reform law. This information does NOT attempt to summarize all provisions of the health care reform law. This information is not and should NOT be used as legal or tax advice; it should not be used as a basis for decisions regarding how health care reform law will affect you and/or your business. Should you have any questions on how the health care reform law (including the high level summary of certain provisions of health care reform) will affect you and/or your business, you should seek professional advice from attorneys or other advisors.