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The eMagazine dedicated to improving members’ well-being

  • Food for thought
  • Exercise good nutrition
  • What to drink when you’re active
  • Soothe your mind, 1 song at a time
  • Saving in the grocery aisles

In each issue you will find information and inspiration to help you with your health and wellness goals.

Whether you eat three or six meals a day, maintaining a healthy weight comes down to what you eat, how much you eat and how much energy you use. We gain weight when we eat more calories than we burn. So it’s really important to couple balanced meals with an active lifestyle.

Everyone has different calorie needs in order to function. Avoiding extra pounds is just a matter of making sure your energy in (calories from food) equals your energy out (daily energy usage) over the long run. Once you learn your daily calorie needs, you can plan the right kind of diet and exercise to keep a healthy weight.

Health affects everything: Your quality of life. Your emotional and mental well-being. Your relationships, work, and finances. Even what you do for fun.

So don’t take your health for granted. Spread a healthy living message to everyone you know. It’s not hard to do. You can ride your bike more and motivate others to do the same. Or start a community garden that gets your neighbors moving and socializing. Good health is contagious, and little choices can make a big impact.

More than 60% of your body is made of water, which you need to function. When you sweat, go to the bathroom or even breathe, you lose a lot of that water. And the best way to get it back is through food and drink.

How much water does the average healthy adult need in a day? There’s no one formula that fits every person, and it depends on things like your age, health, activity level and the climate you live in. But generally, men should drink about 13 cups (3 liters) and women about nine cups (2.2 liters) of water daily.

The eMagazine dedicated to improving members’ well-being

  • Your heart matters
  • Make your ticker — and your taste buds — happy
  • Your heart likes activity
  • Take CAUTION against cancer
  • GOAL SETTING:A blueprint for fitness success
  • Blood pressure: Do you know your numbers?
  • Too much stress can distress your heart

In each issue you will find information and inspiration to help you with your health and wellness goals.

ACAUpdate – Employer Reporting Requirements for Forms 1094B/1095B

The latest – The Internal Revenue Service (IRS) issued Notice 2016-4 on December 28, 2015 which announced a filing extension for Forms 1094B/1095B. The revised deadline for employers to provide Form 1094B to employees is March 31, 2016; and filing Form1095B to the IRS is extended to May 31, 2016 for paper filing, and June 30, 2016 for e-filing.  Notice 2016-4 also extends the filing requirement for health insurance carriers to provide Form 1095C to covered employees to March 31, 2016

Background – Employers with 50 or more full-time (equivalent) employees in 2015, must file Forms 1094-C and 1095-C.  The purpose of this filing is enforcement of the employee and employer mandates of ACA. This information is required under sections 6055 and 6056 regarding offers of health coverage and enrollment in health coverage for employees.

According to the IRS, taxpayers are not required to attach Form 1095C as proof of health care coverage when filing their tax return, but note that employees should keep the 1095C they receive from their employer and 1095B they receive from their insurance carrier as proof of coverage.

For further information regarding Forms 1094B and 1094C, the IRS has provided a Questions and Answers to guide you through the process of filing these forms. Click below for the forms and instructions:

IRS Form 1094/5B


Applies to all small employer plans in California

Background

Two years ago the Affordable Care Act’s mandated premium rating method went into effect for small employers (under 50 employees). As of January 1, 2016, all small employers in California (under 100 employees) must be rated according to the ACA rating method. This ACA mandate applies to all insurance carriers and all groups under 100 employees in California.

Key Takeaways

  • Group and individual employee premium rates may be significantly changing due to ACA’s mandated method of calculating premiums – not due to the base cost of medical insurance.
  • The largest premium increases/decreases tend to be:
    • Younger employees (increase) / older employees (decrease)
    • Family size: one child (decrease); two or more children (increase)
    • Families with children over age 21 (large increase)
    • Spouse’s age higher than the employee (increase); lower than employee (decrease)
    • Employees over age 65 with Medicare secondary rates (increase); Medicare primary (decrease)
    • Employees in certain mandated “rating areas” (increase or decrease)

Premium Rating Rule Changes Explained

The premiums calculated under the ACA and legacy (grandmother or large group) methods can have great differences. Premium rate differences between the methods may be driven by any combination of the four rating variants detailed below.

  1. Age Rating. The ACA mandates that each age has its own specific rate and also mandates the relative premium cost between each age rate. This means that each employee has a birthday increase at the start of every plan year as compared to the legacy method which only had age increases when employees crossed an age band threshold (20-29; 30-40, etc.).Compared to the legacy rating method this mandate increases rates for younger people and lowers rates for the older ages. This can result in rates doubling in the younger ages. Many parents are shocked to learn that the ACA mandates a 57.5% premium increase when their 20 year old dependent child turns 21. This is true for all insurance companies.
  2. Family Rating. ACA mandates that each member of a family is individually age-rated and then summed to an employee total. The legacy method had four rating tiers: employee only; employee+spouse; employee+children; and family. The legacy employee+children and family rating did not consider how many or how old the enrolled children were. Under the ACA mandate, the eldest three children under age 21 in each family are age rated in addition to any dependent children age 21 and older. Families with two or more children, and older children, can see significant premium increases under the ACA method. The legacy method did not consider the spouse’s age. Employee+spouse and family categories can experience sharp differences under the ACA method if the spouse is significantly older or younger than the employee.
  3. Medicare Secondary. Under the legacy rating method employees over age 65 employed by groups with fewer than 20 employees were rated below larger firms because their coverage was secondary to Medicare. ACA’s age rating rules eliminate Medicare secondary rates so all 65+’s are rated the same, which causes the legacy secondary employees to have significant premium increases.
  4. Rating Areas. The legacy rating method had nine (9) rating areas in California. California has mandated 19 rating areas under ACA rating rules. The state did not subdivide the 9 into 19 but redrew many of the boundaries. This can create significant premium variances for certain employees that were previously in a relatively lower/higher rating area and have been assigned to relatively higher/lower premium area.

Analysis

Premiums can increase or decrease, on specific employees, on dependents and on the group in aggregate. In many instances the ACA premium increases tend to affect dependent/spouse costs. Firms typically contribute relatively less towards dependent premiums which transfers much of the increase to the employee. For analyzing premium changes, firms should calculate the amount the premium increase effects their employer contribution versus the employee’s contribution. The ACA rating method can cause disruption in the employer and employee contributions based on the change to the ACA age rates. This may require companies to restructure their employer contributions to mitigate large variations in employer or employee contributions for employee only coverage.

To mitigate the rise in premiums the law has brought about since the implementation of ACA, there has been a trend of employees migrating to lower benefit (higher deductible) plans. Migrating to lower premium plans is a tactic being used by many employers and employees.

Employees with children age 21+ may look to enrolling them in a lower benefit plan in the individual market. The individual market has limited plan choices and provider networks, but these trade-offs may yield a lower premium.

A health insurance captive is an insurance arrangement that is owned and controlled by its insureds.  Mutual insurance companies, Multiple Employer Trusts and Multiple Employer Welfare Arrangements, also have a similar structure.  While a captive can certainly be established and owned by one employer, and many single large employers do own and operate captives, this article will concentrate on the small and mid-size employer captive market.

With a captive the insureds are at risk and therefore can benefit from the underwriting performance and investment income generated by the captive.  They are typically set-up for companies that are too small to self-insure on their own.  By combining a number of employers together they achieve the critical mass to self-insure as a group.  The carrot is that employers will (somehow) achieve a lower cost of providing health benefit plans to their employees than they could through other traditional market options.

Many “captive specialists” have hit the market in recent years promoting health captives as a way for small employers to beat the Affordable Care Act.  These captive consultants do the necessary legal and administrative work to establish a captive on behalf of a potential pool of like-kind employers and then make money through consulting, broker or administration fees for the captive.

Looking under the hood- in a captive, each individual employer is in essence operating a self-funded plan.  Employers take on additional responsibilities and administrative responsibilities in running a self-funded plan, even if the captive is taking on significant portion of the administrative burden.

The captive structure is typically:

  • The employee receives a regular, ACA compliant health benefit plan
  • The employer established a self-funded plan.
    • The captive usually has stock documents for its insureds. The employer has specific and aggregate stop loss insurance purchased through the captive.  The employer pays that actual claims costs for their employees, plus: the administration costs of the captive (which include its reinsurance costs); the stop loss insurance costs; and in the first year or any year the captive has a need, additional capital contribution to the captive (typically 10% or more the first year).
  • The captive purchases reinsurance at levels determined by the size and risk of the captives pool of employers/employees

This structure can of course work, but the gamble is that the captive will have enough critical mass to be able to achieve its promise of outperforming the fully insured market.

California has recently enacted regulations to discourage small employers from sidestepping the ACA small employer pool by using self-funded plans and therefore captives.  The law regulates the minimum amount of the specific and aggregate stop loss small employers (fewer than 100 employees) may purchase, ensuring, in most instances a risk too great for a small employer to assume.  Specific deductibles cannot be below $40,000. Aggregate stop loss minimums are on a formula that requires a risk of at least an additional 20%, or more depending on the specifics of a group.

Upside and downside of a health captive:

The upside is potential cost savings from a number of health plan operating and performance categories.  The most important piece is that claims cost of the captive, in aggregate, outperform the fully insured market in the short and long.  This upside comes with an extremely high risk and is outside of the control of the captives members. Any number of expensive chronic conditions or catastrophic claims can put the captives’ members in a financial disadvantage.  In addition to claims performance, captives usually state that they operate at a lower administrative cost than the fully insured market.  This must be analyzed carefully because the captive has management costs, employer and the captive’s reinsurance costs, and the administrative costs of operating a health plans which have become very complex.  Provider contracts, prescription drug vendors, customer service, appeals, premium billing, large case management, fraud management and many other functions all need to be managed the same as a fully insured carrier.  There are also internal administrative costs and liability to the captives employers that are not incurred with a fully insured plan.  And an employer can have substantial cost to leave a captive or if it is not performing or runs into financial issues.

Captives usually look good from the marketing materials and the mangers who sell them are well versed at handling the risk objections.  For most small employers, particularly in California, the captive arrangement is a financial risk too great and an administrative burden that it does not have expertise in handling.

As mentioned in the first paragraph, a captive and a MEWA Trust like CalCPA Health are similar in that the aggregate a number of smaller employers together.  But the MEWA model provides the participating employers a fully insured health plan, in essence, so it does not subject them to the financial risk and administrative burdens of a captive.

When an employer established an employee benefit plan (ERISA health and welfare plan), any contributions that employee’s make are regulated by ERISA as ERISA plan assets.

There are volumes of regulations regarding the classification and handling of plan assets.  Basically, for small employer health plan contributions, the employer needs to ensure that the amount being deducted from the employee’s payroll is accurate – not more than the required contribution – and that it is remitted to the insurance carrier on the next billing cycle.

Where employers typically run into issues is where and an employee has been making contributions but the employer has not updated eligibility records with their insurance carrier – to add a dependent for example.  The employer is collecting funds from an employee and not remitting to the carrier.

Another common occurrence is when an employee terminates in the middle of a month and they have made one or more premium contributions for the current month and the employer terminated their health coverage at the beginning of the month and does not properly reconcile and return the employees over-payment.

A complete reconciliation of employee contributions is recommended after open enrollment and then individual reconciliations when employees make changes to their eligibility or employment status.