Compliance Guide. Presented By:

Transcription

1 Compliance Guide Presented By: 1

2 Introduction This booklet contains mandatory annual notices regarding your health and welfare benefit plans through Washington Odd Fellows Home for the plan year July 1, 2016 to June 30, Please review these notices carefully and contact us if you have any questions. Human Resources Department Washington Odd Fellows Home Lisa Whited, HR Manager 534 Boyer Ave Walla Walla, WA

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26 Important Notices Women s Health and Cancer Rights The Women s Health and Cancer Rights Act of 1998 (WHCRA) requires that a group health plan, which provides coverage for a mastectomy, must also include coverage for reconstructive surgery and prostheses following the mastectomy. The law mandates that a participant or eligible beneficiary who is receiving benefits for a covered mastectomy and who elects breast reconstruction in connection with the mastectomy, will also receive coverage for: all stages of reconstruction of the breast on which the mastectomy has been performed; surgery and reconstruction of the other breast to produce a symmetrical appearance; prostheses; and treatment of physical complications of all stages of mastectomy, including lymphedemas. Coverage will be provided in a manner determined in consultation with the patient and the patient s attending physician. Benefits will be provided subject to the same deductible and coinsurance applicable to other medical and surgical benefits provided under the plan. If you have any questions about coverage for mastectomies and post-operative reconstructive surgery, please contact your medical plan insurance company. As required under the law, this notice is to be provided upon enrollment and annually thereafter. Newborns and Mothers Health Protection Under the Newborns' and Mothers' Health Protection Act of 1996, group health plans and health insurance issuers offering group health insurance generally may not restrict benefits for any hospital length of stay in connection with childbirth for the mother or the newborn child to less than 48 hours following a vaginal delivery, or less than 96 hours following a cesarean section. However, the plan or issuer may pay for a shorter stay if the attending physician (e.g., your physician, nurse, or midwife, or a physician assistant), after consultation with the mother, discharges the mother or newborn earlier. Also, under federal law, plans and insurers may not set the level of benefits or out-of-pocket costs so that any later portion of the 48-hour or (96-hour) stay is treated in a manner less favorable to the mother or newborn than any earlier portion of the stay. In addition, a plan or issuer may not, under federal law, require that a physician or other health care provider obtain authorization for prescribing a length of stay of up to 48 hours (or 96 hours). However, to use certain providers or facilities, or to reduce your out-of-pocket costs, you may be required to obtain pre-certification. For information on pre-certification, please contact your medical plan insurance company. 26

27 Important Notices HIPAA Special Enrollment Rights Below outlines important information for individuals who are eligible to participate in Washington Odd Fellows Home medical plan (to actually participate, you must complete an enrollment form and may be required to pay part of the premium through payroll deduction). The Health Insurance Portability and Accountability Act of 1996 (HIPAA), requires that you be notified about two very important provisions in the Washington Odd Fellows Home medical plan. The first is your right to enroll in the medical plan under the special enrollment provision if you acquire a new dependent, or you or an eligible dependent decline coverage under the plan because of alternative coverage and later lose such coverage due to certain qualifying reasons. Second, this notice advises you of the plan s preexisting condition exclusion rules that may temporarily exclude coverage for certain preexisting conditions that you or your family may have. I. SPECIAL ENROLLMENT RIGHTS Rule #1 Loss of Coverage. If you are declining enrollment for yourself or your dependents (including your spouse) because of other health insurance coverage for such individuals, and that coverage terminates due to certain qualifying reasons (i.e., exhaustion of COBRA or state law continuation rights; loss of eligibility for other coverage due to legal separation, divorce, death, termination of employment or reduction in hours; or because employer contributions for other non-cobra coverage ceases) you may in the future be able to enroll yourself or your dependents (whose coverage terminates for a qualifying reason) in the plan, provided that you request enrollment within 30 days after your other coverage ends, and that you meet certain other important conditions described in the plan SPD (Summary Plan Description). Rule #2 Marriage, Birth or Adoption. In addition, if you acquire a new dependent as a result of marriage, birth, adoption, or placement for adoption, you may be able to enroll yourself, your spouse, and your newly acquired dependent(s), provided that you request enrollment within 30 days after the marriage, birth, adoption, or placement for adoption, and that you meet certain other important conditions described in the plan SPD. Rule #3 Marriage Equality Act: The Marriage Equality Act revised the rules regarding domestic partnerships in Washington effective June 30, Under the revised rules, domestic partnerships (samesex or opposite- sex partners) may register only if at least one of the partners is age 62 or older and the other eligibility conditions outlined in the State Employment Laws are met. Also, under the Marriage Equality Act, same-sex domestic partnerships that were entered into before June 30, 2014, and have not been dissolved or converted into marriages automatically converted into marriages as of June 30, 2014, unless one of the partners is age 62 or older. 27

28 Important Notices Premium Assistance Under Medicaid and the Children s Health Insurance Program (CHIP) 28

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31 Important Notices Your Prescription Drug Coverage & Medicare Part D Please read this notice carefully and keep it where you can find it. This notice has information about your current prescription drug coverage with Washington Odd Fellows Home and prescription drug coverage available for people with Medicare. It also explains the options you have under Medicare prescription drug coverage and can help you decide whether or not you want to enroll. At the end of this notice is information about where you can get help to make decisions about your prescription drug coverage. There are two important things you need to know about your current coverage and Medicare s prescription drug coverage: 1. Medicare prescription drug coverage became available in 2006 to everyone with Medicare. Coverage may be purchased from insurance carriers that offer Medicare prescription drug plans and Medicare Advantage Plans that include prescription drug coverage. All Medicare prescription drug plans provide at least a standard level of coverage set by Medicare. Some plans may also offer more coverage for a higher monthly premium. 2. Washington Odd Fellows Home has determined that the prescription drug coverage offered by the both Group Health Cooperative and Group Health Options Benefit Plans is, on average for all plan participants, expected to pay out as much as the standard Medicare prescription drug coverage will pay and is considered Creditable Coverage. Because your existing coverage is Creditable Coverage, you can keep this coverage and not pay a higher premium (a penalty) if you later decide to join a Medicare drug plan. When Can You Join A Medicare Drug Plan? You can join a Medicare drug plan when you first become eligible for Medicare and each year from October 15 th through December 7 th. However, if you lose your current creditable prescription drug coverage, through no fault of your own, you will also be eligible for a two (2) month Special Enrollment Period (SEP) to join a Medicare drug plan. Your current coverage pays for other health expenses in addition to prescription drugs. If you enroll in a Medicare prescription drug plan, you and your eligible dependents will still be eligible to receive all of your current health and prescriptions drug benefits. What Happens To Your Current Coverage If You Decide to Join A Medicare Drug Plan? If you decide to join a Medicare drug plan, your current Washington Odd Fellows Home coverage will not be affected. If you do decide to join a Medicare drug plan and drop your current Washington Odd Fellows Home coverage, be aware that you and your dependents will be able to get this coverage back. See pages 7-9 of the CMS Disclosure of Creditable Coverage To Medicare Part D Eligible Individuals Guidance (available at which outlines the prescription drug plan provisions/options that Medicare eligible individuals may have available to them when they become eligible for Medicare Part D. If you do decide to join a Medicare drug plan and drop your current Washington Odd Fellows Home coverage, be aware that you and your dependents will be able to get this coverage back. 31

32 Important Notices Your Prescription Drug Coverage & Medicare Part D continued When Will You Pay A Higher Premium (Penalty) to Join A Medicare Drug Plan? You should also know that if you drop or lose your coverage with Washington Odd Fellows Home and don t join a Medicare drug plan within 63 continuous days after your current coverage ends, you may pay a higher premium (a penalty) to join a Medicare drug plan later. If you go 63 continuous days or longer without creditable prescription drug coverage, your monthly premium may go up by at least 1% of the Medicare base beneficiary premium per month for every month that you did not have that coverage. For example, if you go nineteen months without creditable coverage, your premium may consistently be at least 19% higher than the Medicare base beneficiary premium. You may have to pay this higher premium (a penalty) as long as you have Medicare prescription drug coverage. In addition, you may have to wait until the following November to join. For More Information About This Notice Or Your Current Prescription Drug Coverage Contact the person listed below for further information or call the customer service number on the back of your medical insurance ID card. NOTE: You ll get this notice each year. You will also get it before the next period you can join a Medicare drug plan, and if this coverage through Washington Odd Fellows Home changes. You also may request a copy of this notice from us at any time. For More Information About Your Options Under Medicare Prescription Drug Coverage More detailed information about Medicare plans that offer prescription drug coverage is in the Medicare & You handbook. If you are Medicare eligible, you ll get a copy of the handbook in the mail every year from Medicare. You may also be contacted directly by Medicare drug plans. For more information about Medicare prescription drug plans: Visit medicare.gov Call your State Health Insurance Assistance Program (see the inside back cover of your copy of the Medicare & You handbook for their telephone number) for personalized help. Call MEDICARE ( ). TTY users should call If you have limited income and resources, extra help paying for Medicare drug coverage is available. For information about this extra help visit Social Security on the web at socialsecurity.gov, or call them at (TTY ). Remember: Keep this Creditable Coverage notice. If you decide to join one of the Medicare drug plans, you may be required to provide a copy of this notice when you join to show whether or not you have maintained creditable coverage and, therefore, whether or not you are required to pay a higher premium (a penalty). Name of Entity/Sender: Contact Position/Office: Date: May 12, 2016 Washington Odd Fellows Home Lisa Whited, HR Manager Address: 534 Boyer Ave Walla Walla, WA Phone Number:

33 Important Notices Reminder of Continuation of Coverage Under COBRA Introduction You are receiving this notice because you have recently become covered under a group health plan (the Plan). This notice contains important information about your right to COBRA continuation coverage, which is a temporary extension of coverage under the Plan. This notice generally explains COBRA continuation coverage, when it may become available to you and your family, and what you need to do to protect the right to receive it. The right to COBRA continuation coverage was created by a federal law, the Consolidated Omnibus Budget Reconciliation Act of 1985 (COBRA). COBRA continuation coverage can become available to you when you would otherwise lose your group health coverage. It can also become available to other members of your family who are covered under the Plan when they would otherwise lose their group health coverage. For additional information about your rights and obligations under the Plan and under federal law, you should review the Plan s Summary Plan Description or contact the Plan Administrator. What is COBRA Continuation Coverage? COBRA continuation coverage is a continuation of Plan coverage when coverage would otherwise end because of a life event known as a qualifying event. Specific qualifying events are listed later in this notice. After a qualifying event, COBRA continuation coverage must be offered to each person who is a qualified beneficiary. You, your spouse, and your dependent children could become qualified beneficiaries if coverage under the Plan is lost because of the qualifying event. Under the Plan, qualified beneficiaries who elect COBRA continuation coverage must pay for COBRA continuation coverage. If you are an employee, you will become a qualified beneficiary if you lose your coverage under the Plan because either one of the following qualifying events happens: Your hours of employment are reduced, or Your employment ends for any reason other than your gross misconduct. If you are the spouse of an employee, you will become a qualified beneficiary if you lose your coverage under the Plan because any of the following qualifying events happens: Your spouse dies; Your spouse s hours of employment are reduced; Your spouse s employment ends for any reason other than his or her gross misconduct; Your spouse becomes entitled to Medicare benefits (under Part A, Part B, or both); or You become divorced or legally separated from your spouse. Your dependent children will become qualified beneficiaries if they lose coverage under the Plan because any of the following qualifying events happens: The parent-employee dies; The parent-employee s hours of employment are reduced; The parent-employee s employment ends for any reason other than his or her gross misconduct; The parent-employee becomes entitled to Medicare benefits (Part A, Part B, or both); The parents become divorced or legally separated; or The child stops being eligible for coverage under the plan as a dependent child. 33

34 Important Notices Reminder of Continuation of Coverage Under COBRA continued When is COBRA Coverage Available? The Plan will offer COBRA continuation coverage to qualified beneficiaries only after the Plan Administrator has been notified that a qualifying event has occurred. When the qualifying event is the end of employment or reduction of hours of employment, death of the employee, or the employee s is becoming entitled to Medicare benefits (under Part A, Part B, or both), the employer must notify the Plan Administrator of the qualifying event. You Must Give Notice of Some Qualifying Events For the other qualifying events (divorce or legal separation of the employee and spouse or a dependent child s losing eligibility for coverage as a dependent child), you must notify the Plan Administrator within 60 days after the qualifying event occurs. You must provide this notice to: Northwest Administrators COBRA Department 2323 Eastlake Avenue E Seattle, WA How is COBRA Coverage Provided? Once the Plan Administrator receives notice that a qualifying event has occurred, COBRA continuation coverage will be offered to each of the qualified beneficiaries. Each qualified beneficiary will have an independent right to elect COBRA continuation coverage. Covered employees may elect COBRA continuation coverage on behalf of their spouses, and parents may elect COBRA continuation coverage on behalf of their children. COBRA continuation coverage is a temporary continuation of coverage. When the qualifying event is the death of the employee, the employee's becoming entitled to Medicare benefits (under Part A, Part B, or both), your divorce or legal separation, or a dependent child's losing eligibility as a dependent child, COBRA continuation coverage lasts for up to a total of 36 months. When the qualifying event is the end of employment or reduction of the employee's hours of employment, and the employee became entitled to Medicare benefits less than 18 months before the qualifying event, COBRA continuation coverage for qualified beneficiaries other than the employee lasts until 36 months after the date of Medicare entitlement. For example, if a covered employee becomes entitled to Medicare 8 months before the date on which his employment terminates, COBRA continuation coverage for his spouse and children can last up to 36 months after the date of Medicare entitlement, which is equal to 28 months after the date of the qualifying event (36 months minus 8 months). Otherwise, when the qualifying event is the end of employment or reduction of the employee s hours of employment, COBRA continuation coverage generally lasts for only up to a total of 18 months. There are two ways in which this 18-month period of COBRA continuation coverage can be extended. 34

35 Important Notices Reminder of Continuation of Coverage Under COBRA continued Disability extension of 18-month period of continuation coverage If you or anyone in your family covered under the Plan is determined by the Social Security Administration to be disabled and you notify the Plan Administrator in a timely fashion, you and your entire family may be entitled to receive up to an additional 11 months of COBRA continuation coverage, for a total maximum of 29 months. The disability would have to have started at some time before the 60th day of COBRA continuation coverage and must last at least until the end of the 18-month period of continuation coverage. Requests for disability extension must be made in writing to the plan administrator. Northwest Administrators COBRA Department 2323 Eastlake Avenue E Seattle, WA Second qualifying event extension of 18-month period of continuation coverage If your family experiences another qualifying event while receiving 18 months of COBRA continuation coverage, the spouse and dependent children in your family can get up to 18 additional months of COBRA continuation coverage, for a maximum of 36 months, if notice of the second qualifying event is properly given to the Plan. This extension may be available to the spouse and any dependent children receiving continuation coverage if the employee or former employee dies, becomes entitled to Medicare benefits (under Part A, Part B, or both), or gets divorced or legally separated, or if the dependent child stops being eligible under the Plan as a dependent child, but only if the event would have caused the spouse or dependent child to lose coverage under the Plan had the first qualifying event not occurred. If You Have Questions Questions concerning your Plan or your COBRA continuation coverage rights should be addressed to the contact or contacts identified below. For more information about your rights under ERISA, including COBRA, the Health Insurance Portability and Accountability Act (HIPAA), and other laws affecting group health plans, contact the nearest Regional or District Office of the U.S. Department of Labor s Employee Benefits Security Administration (EBSA) in your area or visit the EBSA website at (Addresses and phone numbers of Regional and District EBSA Offices are available through EBSA s website.) Keep Your Plan Informed of Address Changes In order to protect your family s rights, you should keep the Plan Administrator informed of any changes in the addresses of family members. You should also keep a copy, for your records, of any notices you send to the Plan Administrator. Plan Administrator Contact Information You may obtain information about the Plan and COBRA coverage on request from: Northwest Administrators COBRA Department 2323 Eastlake Avenue E Seattle, WA

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38 This compliance guide created for Washington Odd Fellows Home by Brown & Brown Insurance