affordable care act and its impact on senior living: compliance and solutions

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1 Agenda ACA Timeline Willis Health Care Reform Survey Results Guidance on Health Care Reform Strategies for Consideration Leveraging your ALFA Membership Opportunities for Group Leveraging and Purchasing Benefit Administration Record Keeping

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Willis Senior Living Practice Group will cover the most recent health-care reform legislative updates. Highlights of this session will include a review of the Affordable Care Act compliance requirements and specific strategies for the senior living industry. The panelists will discuss administration requirements and solutions, innovative benefit designs, enrollment solutions, and group purchasing opportunities. >> Faculty: Michael Pokora, Managing Director, Willis Senior Living Practice || Michael Taggert, President, Empyrean || Gregory J. Martens, EVP Managing Director, Willis Human Capital Practice

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Page 1: Affordable Care Act and Its Impact on Senior Living: Compliance and Solutions

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Agenda   ACA Timeline •  Willis Health Care Reform Survey Results

  Guidance on Health Care Reform

  Strategies for Consideration

  Leveraging your ALFA Membership •  Opportunities for Group Leveraging and Purchasing •  Benefit Administration •  Record Keeping

Page 2: Affordable Care Act and Its Impact on Senior Living: Compliance and Solutions

2010 2011 2012 2013 2014 2015 2016 2017 2018 2019 2020

Entire Law Upheld

ACA: Timeline •  SBC Coverage Summary •  W-2 Cost Reporting •  PCORI Fee •  MLR Payouts •  Women’s Preventive

Services •  Internal and External

Review

•  FSA $2,500 Limit •  2.3% Medical Device Tax •  .9% FICA – Med Surtax on High Earners •  Itemize Medical at 10@ AGI (up from 7.5%) •  PCORI fee Increase •  Notice of State Exchanges and Subsidies •  Elimination of Medicare Part D Tax Deduction

•  Individual Mandate •  Employer Mandate – Essential, Affordable •  State Exchanges – Taxpayer – paid Credits •  Annual Dollar Limit on EHB Lift •  90 Day Wait Maximum •  Adult Child Grandfather Ends •  Cafeteria Plans Permitted for Exchange Coverage •  Pre-ex Ends For All •  Medicaid Expansion •  New Tax on Health Insurers •  Reinsurance Fee •  Enhanced Wellness Financial Incentives •  OOPM Limit = HSA Limit

•  Delayed Provisions •  Auto Enrollment (> 200) •  Insured Non Discrimination

Testing

•  State Exchanges – Potential Expansion to Large Employers

•  “Cadillac Excise Tax”

•  All State Exchanges Open to <100

•  Part D “Donut Hole” Phase Out Complete

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Page 3: Affordable Care Act and Its Impact on Senior Living: Compliance and Solutions

Willis National Health Care Reform Survey – What We Have Learned   Employers will continue many existing strategies •  Expansion of Wellness Offering •  Redesign of benefit options and eligibility provisions

  Most employers plan to “play” under the “play or pay” mandate •  Continuation of the “compliance as we go” approach as opposed

to adopting a Total Rewards strategy   Employers are concerned with cost, but underestimate the cost of

compliance •  60% of employers say that avoiding cost increases is the most

important consideration for their businesses •  Over half of surveyed employers have not determined the cost of

Health Care Reform compliance

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Page 4: Affordable Care Act and Its Impact on Senior Living: Compliance and Solutions

  Federal exchange for 32 states o  Initial open enrollment to start

10/1/13   19 states/DC establish

exchanges   7 partnership exchanges   25 states default to federal

exchange   Question about tax credits and

penalties for coverage on federal exchange

Federal Healthcare Reform Public Exchanges

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Page 5: Affordable Care Act and Its Impact on Senior Living: Compliance and Solutions

Guidance on Health Reform

  Pay or Play” rules - Large employers must offer affordable health coverage (meeting MEC rules) to substantially all FTEs

  Case study •  Happy Village – 1000 employees (930 salaried; 70 hourly) •  Health coverage offered only to salaried employees

  Issue 1 – Offering coverage to substantially all FTEs •  Regulations provide a 5% allowance for offering coverage •  Happy Village fails the 95% test •  Penalty is $2,000 for each FTE (less 30) prorated monthly •  Happy Village penalty is $1,940,000 annually

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Page 6: Affordable Care Act and Its Impact on Senior Living: Compliance and Solutions

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Guidance on Health Reform

  Issue 2 - Determining FTEs •  Ongoing Employees vs. New Hires ‒  Standard Measurement Period ‒  Stability Period ‒  Administrative Period

•  Nuanced rules for ‒  Different categories of employees ‒  Seasonal employees ‒  Mid year employment status changes ‒  Rehires

Page 7: Affordable Care Act and Its Impact on Senior Living: Compliance and Solutions

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Guidance on Health Reform

SMP “Lookback Period” 6 months AP 2014

Stability Period = Calendar Year

Case Study for Ongoing FTE Calculation

10/1/13 4/1/13

1/1/2014 1/1/2015

Managing the Variable Hourly EE Eligibility Requirements

SMP “Lookback Period” 12 months AP 2015 Stability Period

10/1/14

SMP “Look Back” Period 12 Months

Transition Year

SMP – Standard Measurement Period AP – Administration Period SP – Stability Period

Page 8: Affordable Care Act and Its Impact on Senior Living: Compliance and Solutions

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Guidance on Health Reform

2015 Stability Period = Calendar Year

1/1/2015 1/1/2016

Managing the Variable Hour EE Eligibility Requirements – New Hires

SMP “Lookback Period” 12 months AP

2016 Stability Period

10/1/14

SMP “Look Back” Period 12 Months

New Hire “Initial Lookback Period” 12 months

1/1/2014

6/1/14 6/1/15

10/1/14 9/30/15

Initial Stability Period

10/1/15

2016 Stability Period

Page 9: Affordable Care Act and Its Impact on Senior Living: Compliance and Solutions

Federal Healthcare Reform Public Exchanges

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Page 10: Affordable Care Act and Its Impact on Senior Living: Compliance and Solutions

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Guidance on Health Reform

  Pay or Play” rules - Large employers must offer affordable health coverage (meeting MEC rules) to substantially all FTEs

  Issue 3 - Affordable health coverage – cost of single coverage is not more than 9.5% of household income

•  Safe harbor rule – single coverage cost not more than 9.5% of

employee pay (Box 1 of W-2)

•  Penalty - $3,000 for each employee who obtains coverage and premium assistance through a state exchange (prorated monthly)

Page 11: Affordable Care Act and Its Impact on Senior Living: Compliance and Solutions

  Meet all PPACA requirements

  Continue employer sponsored healthcare model

  Plan remains affordable for all employees

  Tweak/Adjust existing coverage, contributions, reporting, etc.

  Meet some PPACA requirements

  Allow low wage workers to qualify for government subsidies/ Medicaid

  Pay $3,000 penalty for those ee’s who leave plan and receive subsidy

  Increase cost sharing for dependents, and/or eliminating spouses coverage

Option 1

Maintain Status Quo

Option 2

Mostly Play

Option 3

Compliant Creative Strategy

  Meet all PPACA requirements

  Offer minimum possible coverage that would avoid penalties

  60% plan design with no coverage for spouses

  Contributions set at 9.5% of wages for self-only coverage, and 100% cost for child coverage

Strategies for Consideration

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Page 12: Affordable Care Act and Its Impact on Senior Living: Compliance and Solutions

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Strategies for Consideration: Example of a “Redesign”   Offer a multi plan offering to meet minimum compliance guidelines while

offering affordable options to all employees

Plan A

Current Medical

Option(s)

Estimate: $850 PEPM

Plan B

“Bronze Option” for

ACA Compliance

Estimate: $400 PEPM

Plan C

Fixed Indemnity, Hospital

Confinement, Critical Illness,

and Accident

Estimate: $250 PEPM

Cost may vary based on plan designs offered

Tradition Plan(s)

Minimum Compliance

Plan

Alternative Reimbursement

Plans

Page 13: Affordable Care Act and Its Impact on Senior Living: Compliance and Solutions

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Strategies for Consideration: “Defined Contribution”   Provide all employees

equal amount to spend on healthcare and ancillary benefits with a wide range of choices and allow employees to select coverage based on their risk preferences

Page 14: Affordable Care Act and Its Impact on Senior Living: Compliance and Solutions

TECHNOLOGY & SERVICES CONSULTING & DESIGN

Integrated Benefit Administrator and ACA Compliance Technology

Plan Design Management (Design) •  Health & Welfare Plan Design •  Financial Budgeting/Underwriting •  Employee Communication

Vendor Management (Deploy) •  Contract Management/Renewal •  Performance Standards and Audits •  Implementation

Account Management (Define) •  Strategic Planning •  Compliance Management •  Program Implementation

Benefit Exchanges (Design) •  Total Benefit Marketplace •  Supports Legacy Plans •  Supports Defined Contribution

Traditional Administration (Define) •  Highly Flexible Implementation •  Employee Benefit Portal •  Call Center

Regulatory Compliance (Deploy) •  Compliance Testing Process •  Integration with HRIS •  Record Keeping

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ACA Total Solution Delivery

Page 15: Affordable Care Act and Its Impact on Senior Living: Compliance and Solutions

- Solution Spectrum +

Benefit Administration

Only

Maintain Existing “Core Benefits”

and offer Alternative

Reimbursement Plans

Maintain Existing “Medical Benefits” and offer

Ancillary Plans

Adopt Full ALFA Group

Purchasing Strategy

Defined Contribution Marketplace

•  Employee Benefit Portal

•  Online Enrollment •  Call Center •  Improved Employee

Communication •  Eligibility

Management •  ACA Record Keeping •  Reduce HR Team

workload

•  Benefit Administration

•  Continue current Medical, Dental, Life and Disability carriers

•  Offer Alternative Reimbursement Plans

o  Fixed Indemnity

o  Hospital Confinement

o  Critical Illness o  Accident

•  Benefit Administration

•  Continue current Medical and Dental carriers

•  Offer Ancillary Plans o  Life o  Disability o  Fixed

Indemnity o  Hospital

Confinement o  Critical Illness o  Accident

•  Benefit Administration

•  Offer Choice of Plans o  Medical o  Dental o  Life o  Disability o  Fixed

Indemnity o  Hospital

Confinement o  Critical Illness o  Accident

•  Benefit Administration

•  Provide all employees equal amount to spend on healthcare and ancillary benefits with a wide range of choices and allow employees to select coverage based on their risk preferences

+ Cost of Benefit Administration -

ALFA Solution - Group Leveraging Strategy Preferred Pricing from Carriers

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Page 16: Affordable Care Act and Its Impact on Senior Living: Compliance and Solutions

ALFA Solution – Preferred Pricing Carriers

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Medical

Dental

Vision

Life and Disability

Voluntary

Stop Loss (Self Insured Medical)

Page 17: Affordable Care Act and Its Impact on Senior Living: Compliance and Solutions

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Questions?