GRANDFATHERING & TRANSITION RELIEF

Transcription

1 GRANDFATHERING & TRANSITION RELIEF

2 Grandfathering The Promise If you like your health plan, you can keep it. Requirements Grandfathering Provision 2010 Changes 2014 Changes Administrative Fix Transition Relief 2

3 Requirements Cannot Raise Co-Insurance Charges. Cannot Significantly Raise Co-Payment Charges. Cannot Significantly Raise Deductibles. Cannot Significantly Lower Employer Contributions. Cannot Add or Tighten an Annual Limit on What the Insurer Pays.

4 Grandfathered Benefits 2010 Source:

5 Lots of non-grandfathered plan changes The government thought these changes were so important that all plans needed to implement them, whether they were grandfathered or not.

6 Non-Grandfathered Benefits, 2010 No annual or lifetime limits on essential benefits. No rescission of coverage is permitted except in cases of fraud or intentional misrepresentation. All group and individual plans, including self-insured plans, will have to cover pre-existing conditions for children 19 and under for plan years beginning on or after 6 months after the date of enactment. Coverage of young adults up to age 26 on their parents health plan

7 Is there any reason to stay grandfathered at this point? Yes!! Initially, there wasn t much incentive to stay grandfathered, and many groups weren t even given the choice by their carriers. Now, though, any group that is grandfathered should stay that way. Grandfathered group avoid: OOP limits Actuarial value requirements Essential benefits, including pediatric dental and vision on small group and maternity on individual plans Coverage of clinical trials Modified adjusted community rating

8 How many are still Grandfathered? Not a lot 8

9 Millions Received Termination Letters 9

10 Negative Publicity, Declining Poll Numbers 10

11 TRANSITIONAL RELIEF 11

12 Transition Relief Keep Sub-Standard Plans Source: 12

13 States & Carriers have option to renew non-compliant plans Source: 13

14 Sort of like grandfathering As provided in the November 14, 2013 letter, policies subject to the transitional relief are not considered to be out of compliance with the following provisions of the Public Health Service Act (PHS Act): Section 2701 (relating to fair health insurance premiums); Section 2702 (relating to guaranteed availability of coverage); Section 2703 (relating to guaranteed renewability of coverage); Section 2704 (relating to the prohibition of pre-existing condition exclusions or other discrimination based on health status), with respect to adults, except with respect to group coverage; Section 2705 (relating to the prohibition of discrimination against individual participants and beneficiaries based on health status), except with respect to group coverage;1 Section 2706 (relating to non-discrimination in health care); Section 2707 (relating to comprehensive health insurance coverage); Section 2709, as codified at 42 U.S.C. 300gg-8 (relating to coverage for individuals participating in approved clinical trials); Additionally, policies subject to the transitional relief are not considered to be out of compliance with section 1312(c) of the Affordable Care Act (relating to the single risk pool requirement). As a reminder, issuers can choose to adopt one or all of these provisions in their renewed policies. Source: 14

15 Two more years, and maybe one more Source: 15

16 Also applies to large groups that will be small groups in 2016 Source: 16

17 States can implement none, some, or all of transitional relief Source: 17

18 New notice requirements Health insurance issuers that renew coverage under this extended transitional policy through October 1, 2016, must, for each policy year, provide the relevant attached notice to affected individuals and small businesses as specified in our November 14, 2013 guidance. Source: 18

19 Hardship extension available until 10/1/16 Source: 19

20 FAQs on Transition Relief to ACA Compliant Plans Source: 20

21 Non-compliant coverage not considered out of compliance Source: 21

22 Need to read this one three times Source: 22

23 Groups with employees can switch carriers Source: 23

24 Individuals and small employers that switched carriers Source: 24

25 Old plans can t be reinstated Source: 25

26 For 51-99, even applies to new groups Source: 26

27 Transitional policies ARE minimum essential coverage Source: 27

28 Transition Relief Can renew with current, non-compliant plan (just like being grandfathered without being grandfathered) Same benefits and rating rules as in the past Unhealthy groups probably won t want to take advantage of this (they should have already move to ACA-compliant plans) Healthy groups may have a higher renewal because carriers still need to offset the cost of the unhealthy groups who aren t paying as much now.

29 Grandfathering and Transition Relief ANY QUESTIONS? 29