Health Care Reform

On March 23, 2010, President Obama signed federal health care reform into law, also known as the Patient Protection and Affordability Act. A second, or reconciliation, bill was also signed by the President shortly after. This page addresses the details of the legislation and will be updated as more information becomes available. If you have additional questions, please e-mail your HealthPartners sales representative or healthcarereform@healthpartners.com.

Overview

We are working diligently to figure out exactly what this legislation means. As your health care partner, we vow to be a trusted resource to help guide you through all the details.

Please note that these documents are subject to further clarification and correction. Many of the provisions are subject to change and/or are awaiting further guidance from regulators.

• Notices you are required to provide your employees on your first renewal after September 23, 2010
• Review the Frequently Asked Questions
• View a summary of the bills

Standardized Summaries of Benefits and Coverage

Health care reform requires that all individual and group plans, regardless of grandfathered status, provide standardized summaries of benefits and coverage beginning on March 23, 2012.

• Learn more about the requirement.
• Review the proposed template.

Mega-Reg overview

The Mega-Reg provides guidance on many of the near-term impacts of health care reform. During June 2010, the Interim Final Rule provided guidance on many provisions of health care reform that must be implemented as groups renew on or after September 23, 2010. Learn more about the requirements. Use this model notice to notify employees of the removal of lifetime limits.

Grandfathered plan status

Health care reform establishes criteria for “grandfathered” plans, which are not required to adopt some of the provisions of health care reform. The Interim Final Regulation on grandfathered plans was released in June 2010 and clarifies what constitutes a grandfathered plan as well as how a plan or policy can retain its “grandfathered status”.

• Learn more about grandfathered status
• Use this checklist to see which changes would cause a plan to lose its grandfathered status
• View an overview of the health care reform exemptions for grandfathered plans

Dependents to age 26 provision

Under federal health care reform that will go into effect upon renewal, on or after September 23, 2010, the definition of “dependent” will change. At that time, dependents must be covered by health plans up to age 26. To prevent young adults from losing coverage due to age in the interim, we extended dependent coverage from age 25 to age 26 for fully insured plans in May 2010.

• Review the full impact of this provision
• Learn more about HealthPartners’ early implementation of this provision
• Use the model notice to notify your employees of this new eligibility

Early Retiree Reinsurance Program (ERRP)

The Early Retiree Reinsurance Program (ERRP) is a provision of federal health care reform that establishes a reinsurance program for employer-based early retiree plans. This program pays for up to 80 percent of the expenses incurred and paid between $15,000 and $90,000 per eligible early retiree, spouse or dependent, per plan year. Learn more about the how HealthPartners can help with the application.

Documents to submit with your ERRP application:

• Information on HealthPartners cost-saving programs for high-cost and chronic conditions
• Information on HealthPartners Fraud, Waste & Abuse prevention practices
• An overview of how you could use the reimbursement money

To learn more about the ERRP or to apply, visit errp.gov.

Consumer-directed health plan (CDHP) changes

Health care reform includes several short-term changes to CDHPs, many of which go into effect on January 1, 2011. Learn more about these changes. Use this sample communication to let your employees know about this change.

Changes to appeals and external review requirements

Health care reform sets forth new requirements for appeals and extends external review requirements to self-insured plans. Previously, external review obligations only applied to fully insured plans. These changes go into effect the first time a plan is renewed on or after September 23, 2010. Learn more about the requirements.

Small business health care tax credit

A provision of health care reform provides small business tax credits beginning in 2010. This tax credit is designed to be an incentive for small businesses to offer heath care coverage to their employees through January 1, 2014. Beginning in 2014, employers must participate in the exchange to get a tax credit. Learn more by clicking the links below from the IRS:

Non-discrimination testing requirements

Health care reform extends the Internal Revenue Service (IRS) non-discrimination requirements that previously only applied to self-insured plans to all fully insured, non-grandfathered plans beginning as plans renew on or after September 23, 2010. At the end of December 2010, the Internal Revenue Service (IRS) announced that compliance with non-discrimination rules for fully insured plans will not be required until the agencies issue regulations or other guidance regarding the rules. More information will be posted once the guidance becomes available.

W-2 reporting requirements

Health care reform includes new requirements for reporting the cost of employer-sponsored health care coverage on employees' W-2. This reporting is optional for tax year 2011 but is required for tax year 2012 (W-2s sent by January 31, 2013). For more information, please contact your payroll administrator or broker, or learn more by clicking on the links from the IRS below.