Health Care Reform Checklist for 2011

The Patient Protection and Affordable Care Act (PPACA) contains comprehensive health insurance reforms that require compliance by employer-sponsored group health plans. Many of these reforms apply to plan years beginning on or after September 23, 2010. The following general checklist is designed to help employers review their plan’s compliance with the major health care reform requirements implemented in 2010, as well as prepare for changes ahead in 2011.

Please note that this list is for general reference purposes only and is not all-inclusive. This list is also subject to change based on new government requirements or directives. Additionally, your group plan may be exempt from certain requirements described below. If you have any questions regarding your
obligations with respect to health care reform, you should consult with a knowledgeable employment law attorney and your carrier for specific guidance.

1. Determine Grandfathered or Non-Grandfathered Status of Plan

Note: A grandfathered plan is one that was in effect on March 23, 2010. If a plan loses its grandfathered
status, it may no longer be exempt from certain PPACA requirements.

Evaluate whether any changes made to the group health plan with respect to benefits,
costs, or other changes result in
loss of grandfathered status.
To maintain grandfathered status, a plan must include a statement, whenever a summary of benefits
under the plan is provided to participants and beneficiaries, that the plan believes it is a grandfathered
health plan according to the Affordable Care Act and must provide contact information for questions and
complaints (model notice available here).

2. Review Plan Documents for Required Changes

Note: Unless otherwise noted, plan documents should be amended to reflect changes effective as of the
first day of the first plan year beginning on or after September 23, 2010. Please consult with your
carrier for additional details or if you have questions regarding these amendments.

If the plan offers dependent coverage, the coverage is available until a child reaches the age of 26.
(Prior to 2014, grandfathered plans do not have to comply with this requirement for adult children who have another offer of employer-based coverage.)
Lifetime dollar limits on “essential health benefits” have been eliminated.
Annual limits on “essential health benefits” are being phased out according to the limits set by law (no lower
than $750,000 for plans issued or renewed beginning Sept. 23, 2010). Some plans may be eligible for a
waiver from the rules concerning annual dollar limits.
Any pre-existing condition exclusions for children under age 19 have been eliminated.
Effective Jan. 1, 2011, reimbursements for over-the-counter drugs from HSAs, Archer MSAs, FSAs or HRAs qualify
only if the medication is purchased with a prescription (except insulin). An increased penalty of 20% applies for nonqualified distributions from a HSA or Archer MSA.
Except for grandfathered plans, coverage of recommended preventive services is provided with no cost-sharing requirements, such as co-payments or deductibles.
Except for grandfathered plans, patient protections related to choosing a primary care provider, access to OB/GYN care, and coverage of emergency services are included as appropriate.
Except for grandfathered plans, an effective internal and external appeals process for coverage determinations and claims is in place.

3. Implement Special Enrollment Opportunities

Note: The following special enrollment opportunities must be provided, and coverage must take effect,
not later than the first day of the first plan year beginning on or after September 23, 2010.

30-day special enrollment opportunity for individuals whose coverage ended, or who were denied coverage (or were not eligible for coverage), because the availability of dependent coverage of children ended before attainment of age 26.
30-day special enrollment opportunity for individuals whose coverage ended by reason of reaching a lifetime limit under the plan.

4. Provide Participant Notices

Note: Unless otherwise noted, the following notices should be provided to plan participants no later than the first day of the first plan year beginning on or after September 23, 2010.

Opportunity to enroll in connection with extension of dependent coverage to age 26 (model notice available here).
Lifetime limit no longer applies and opportunity to enroll (model notice available here).
Notice of patient protections, if applicable (model notice available here). Distribute whenever a participant is
provided with a summary plan description or other similar description of benefits under the plan, and no later than the
first day of the plan year starting on or after Sept. 23, 2010.
Notice of available internal and external appeals processes and the availability of any consumer assistance with respect to such processes, if applicable.
It is also prudent to provide participants notice of the new restrictions on reimbursement of costs for over-the-counter drugs in relation to HSAs, Archer MSAs, FSAs and HRAs, prior to Jan. 1, 2011.

5. Other Considerations

Review and amend Section 125 (cafeteria plan) documents as necessary to reflect any changes. If eligible, consider whether your company could benefit from establishing a simple cafeteria plan.
Determine whether your company qualifies for the small business health care tax credit.
Maintain compliance with the break time requirement for nursing mothers, if applicable.
Consider necessary changes to your payroll system in preparation for compliance with the requirement to report employer-provided health coverage on Form W-2. Reporting by employers is optional in 2011.*
Be prepared for compliance requirements to change. Stay up-to-date on the latest information regarding health care reform by visiting
HealthCare.gov.

Please note that employers in some states may be required to report the cost of employer-provided health benefit coverage for adult children on the employee’s Form W-2 in 2011 for state income tax purposes. Employers should contact their state revenue department for reporting requirements related to coverage for adult children.

Stay informed about the latest in HR and payroll news, trends, best practices and evolving legislation. Sign up for the monthly Ascentis HR, Benefits and Payroll News.

Do You Have the Open Enrollment Blues?

If you’re like most individuals working in Human Resources you know all too well how overwhelming open enrollment can be not only for your HR staff, but also the rest of the organization. According to SHRM, HR Managers spend “an estimated 25 to 30 percent of their time managing employee benefits.” During an open enrollment period that number increases, to the degree that some HR departments even bring in temporary labor to assist with the influx of inquires. Other times, a company will simply outsource inquiries to a call center, incurring additional costs. Since the Healthcare Reform Act was passed there is even more information that your employees need, and many more laws with which you must be in compliance. Many companies are trying to find more efficient ways to keep their employees informed on the heath care plans and information. In this post, we’ll discuss open enrollment, the major responsibilities of HR, and some ways to improve the overall open enrollment process and experience.

Simply put, open enrollment is a period of time your employees enroll in benefits or change from one plan to another. After open enrollment is closed, the employee coverage is locked until the next open enrollment period begins. To ensure employees choose the healthcare plan that fits them best, companies dedicate countless hours, additional resources and lots of time ensuring that employees are informed. After all, we want our employees to be happy and healthy, because a happy worker is a productive worker.

Some of the major responsibilities for HR during open enrollment include choosing a benefits package, selecting and preparing communications for employees, setting the stage to make it easy for employees to complete open enrollment and keying updates and changes into additional systems. In each of these responsibilities comes an element of change management. Through the use of today’s available HRIS/HRMS tools, companies are finding it easier to manage the open enrollment process. A great example of such a tool is AscentisHR which is a fully integrated solution connecting open enrollment, self-service and HR administration together as one. The truth is that open enrollment need no longer be a pain point. It doesn’t have to be so arduous or time consuming for HR or for the employee. Employee Self-Service is the answer.

What Self-Service Looks Like. Literally.

Click on this image to see the full screenshot

The self-service open enrollment wizard provides a straightforward and intuitive approach to guide and inform employees on benefit selection. The system allows the employees to compare benefits side-by-side, elect alternative plans, submit benefits electronically to the carrier, and much more. Outside of open enrollment, the onus is placed on the employee to update their personal information throughout the year, taking the burden off of HR. Click here learn more about self-service and other Ascentis solutions.

For more information, or to request a product demonstration, fill out this short form and we’ll show you how we can help your Human Resources department be more accelerated, efficient and compliant. Subscribe to our monthly newsletter, the Ascentis HR, Benefits and Payroll News, and stay on top of industry news, best practices and always-evolving legislation. Follow Ascentis on Twitter and “Like us” on Facebook to receive great HR, payroll and business tips. Feel free to share this post using the built-in share buttons below this post.

Watch this archived webinar to learn how adding employee self service your HR technology toolbelt can automate and accelerate the open enrollment process, virtually eliminate costly errors and make employees (and yes, even HR) happier during the open enrollment process. Or, for a bigger picture overview, this four minute self service demo, will give you all the info you need to determine if you want to learn more.

The ABCs of Connecting Electronically to Your Insurance Carriers

By Dwight Matheny, Ascentis Vice President and General Manager

So you’re tired of the paper mess around open enrollment and you’re thinking in the age of the Web there must be a better way, right? There is definitely a better way, but actually doing it on your own is not for the faint of heart. Many people don’t know the process and complexities involved, and many vendors have little experience in this area. That’s why it’s so important to partner with an HRIS or HR software vendor that has years of experience in this process. If you choose to do it yourself, you’ll have greatest success if you follow these critical steps:

Step 1: Negotiate - Will your carrier be interested in allowing connectivity from your company to their systems? How are your skills in negotiating with an insurance carrier? If your company is in the 100-1,000 employee range, will carriers be interested in dealing with you or will they only want to deal with larger groups where there is a greater return for them?

Step 2: Review the Carrier’s Companion Guide - What’s a companion guide? Isn’t there a federally mandated standard format? Well, yes … but carriers generally have a long list of enhancements, interpretations, and additions to the standard, and so they put those into a Companion Guide. Here’s a few examples from EyeMed, Independence Blue Cross, and AmeriHealth. These are all fun documents you can read in your spare time.

Step 3: Get the right technology - Get the right technology to securely communicate with the carrier. The carrier will let you know what’s required, and, by the way, each carrier is different. Be prepared to learn about encryption, secure transfer methods and other fun topics. And don’t forget to make sure you comply with the federal privacy and security regulations.

Step 4: Get to know 834 and start coding – Be prepared to write some code to get your enrollment data into the federally mandated ANSI X12N 834 file format. Make sure to follow the federal regulations (check out page 50,358… it’s my favorite). You can purchase the documentation on the 834 file format from WPC (only a few hundred pages of fun reading).

Step 5: Testing, testing, 123 - If you’ve made it through steps 1-4, you’re ready to test with your carrier. Could be a slight problem here… many carriers don’t do testing in November or December, and can only test for a couple of clients at a time, so be prepared to wait your turn. We’ve seen anywhere between five and 40 steps in a carrier’s testing processes, so be prepared to be actively involved in the process. You will have to arrange to respond to any errors in your data or programming, fix the errors, and get the new, improved file back to the carrier and then re-test (after getting back into line!). Oh, and did you think about your open enrollment date prior to this?

Step 6: Deploy! - Having passed steps 1-5, you’re ready to start the electronic feeds, and then you’re ready to do this again with your other five carriers!

Step 7: The “Are you kidding me?” step - Your CFO decides that it’s time to change carriers. Have a few margaritas, tell your family you’ll see them next year, and start over at Step 1!

Step 8: There’s a better way! - Ascentis specializes in connecting small to mid-sized companies to their carriers electronically through their flagship HRIS product, Ascentis HR. Using the Ascentis Carrier Connect Service, you can transmit data directly to your carriers, and eliminate billing errors and overpayments. If your company also deploys Ascentis Employee Self-Service, Carrier Connect virtually eliminates data errors and offers a truly paperless open enrollment environment. Download the free white paper: Web-based Online Enrollment: How a Paperless Process Saves Time, Eliminates Errors, and Increases Employee Satisfaction. Visit Ascentis for more details, or call 1.800.229.2713.

Model Employer Children’s Health Insurance Program Notice

On February 4, 2009, President Obama signed the Children’s Health Insurance Program Reauthorization Act (CHIPRA) of 2009. CHIPRA includes a requirement that the Departments of Labor and Health and Human Services develop a model notice for employers to use to inform employees of potential opportunities currently available in the State in which the employee resides for group health plan premium assistance under Medicaid and the Children’s Health Insurance Program (CHIP). The Department of Labor was required to provide the model notice to employers within one year of CHIPRA’s enactment.

Through a notice in the February 4, 2010 FEDERAL REGISTER, the Department’s Employee Benefits Security Administration (EBSA) announces the availability of the Model Employer CHIP Notice. The notice provides the “form and content of notice” as well as the “timing and delivery of the notice” while outlining the requirements for addition of state-specific information.

To quickly generate and send this (or any future) notices to your employees, use the Employee Correspondence Wizard (ECW) in Ascentis HR. Create your notice or use the template provided by the Department of Labor here for the Model Employer CHIP notice. Once your notice has been built, open ECW from Employee Manager and create a new correspondence batch. By walking through the ECW you can print or email the notice to all employees you select. Lastly, select to attach the notice to each employee’s record through the ECW as a note. Now your work with this notice is done!

For detailed instructions on using the ECW see the “Employee Correspondence Wizard” section of the Help documentation included in Ascentis HR.

Ascentis Blog

Information to help HR and payroll managers, recruiters, and compliance officers become more effective.

Tag Archives: open enrollment

Health Care Reform Checklist for 2011

Do You Have the Open Enrollment Blues?

The ABCs of Connecting Electronically to Your Insurance Carriers

Model Employer Children’s Health Insurance Program Notice