With a one-year delay until 2015 in the employer pay-or-play penalty, the availability of small business "SHOP" plans, and the higher standards for health insurance benefits in the individual market, all this might lead business owners and individuals to believe not much change will actually be felt in 2014.
2. With a one-year delay until 2015 in the employer pay-or-play penalty, the
availability of small business "SHOP" plans, and the higher standards for
health insurance benefits in the individual market, all this might lead business
owners and individuals to believe not much change will actually be felt in
2014. Be assured, this is a false notion.
www.hrp.net
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» Here is a summary of what key provisions will take effect for plan years which
begin in 2014 (whether on January 1st or some other date during the year).
3. Pre-Existing Condition Exclusions
One provision which has been cited perhaps most frequently by supporters of
the Affordable Care Act, is the elimination of exclusions for pre-existing
conditions. Supporters have particularly pointed to this provision since the
law itself came under fire during the premature roll-out of the public
exchanges for individual coverage.
There is no "free lunch," of course. As employers and individuals getting
health coverage quotes now have recognized, the health plans' increased
exposure to higher claims contributes to a boost in premiums. Yet it can be a
small price for an individual with a chronic, life-threatening disease.
www.hrp.net
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4. Dollar Cap Eliminated
Employers covered by the Affordable
Care Act (that is, those with at least 50
full-time equivalent employees) are not
obligated to cover the full spectrum of
minimum essential benefits until 2015.
They are however, not permitted to put
a dollar cap on those which they do
offer.
In addition, you cannot change your
plan year to postpone becoming subject
to this requirement. A possible
exception, although the rules are
unclear at this point, is whether you can
cap the number of hospital days your
plan will cover.
www.hrp.net
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5. www.hrp.net
These dollar limits ($6,350 for single coverage and $12,700 for family) on the
amount employees can be required to kick in, collectively, pertain to health
services included in the essential health benefits. However, next year you are
permitted to have higher limits for prescription drug and dental plans. (In
2015, that exemption disappears.)
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Out-of-Pocket Maximums
6. Wellness and Preventive Services
Next year you can beef up wellness plan participation incentives to 30 percent of
the cost of health coverage, and half the cost for tobacco cessation programs.
Coverage of preventive services for non-grandfathered plans has been required
for a couple of years already. But that requirement kicks in next year for
grandfathered plans. Grandfathered plans are those which were in existence
when the ACA was enacted in 2010, and haven't reduced benefits significantly
since then.
www.hrp.net
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The required services are based on
recommendations by the U.S. Preventive
Services Task Force, many of which are
identified here. As the old saying goes, the devil
is in the details. You'll need to check with your
health plan providers for how they are
interpreting the guidelines. In theory, making
these services available to your workers without
co-pays could ultimately lower -- or slow the
rate of increase -- of your healthcare spending.
Time will tell.
7. Women's Health Services
Required for non-grandfathered plans since last year, this ACA mandate has
been the subject of considerable controversy and litigation, particularly
focused on birth control. Grandfathered plans will be required to offer the
following services (without a co-pay):
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• well-woman visits
• screening for gestational diabetes
• human papillomavirus testing
• counseling for sexually transmitted infections
• counseling and screening for HIV
• breastfeeding support, supplies, and counseling
• and screening and counseling for interpersonal domestic violence.
8. www.hrp.net
In addition, the hot button "contraceptive methods and counseling" is
supposed to cover "all FDA approved contraceptive methods, sterilization
procedures, and patient education and counseling for all women with
reproductive capacity." This is according to the government's rundown on the
broader topic on this webpage. An exception is provided for religious
institutions.
Also, "accommodations are available to group health plans established or
maintained by certain eligible organizations… as well as student insurance
coverage arranged by eligible organizations" allowing them to opt out of
providing contraception coverage.
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9. 90-Day Waiting Period
The ACA bans waiting periods of longer than 90 days, for new hires to
become eligible to join your health plan. This applies to all eligible employees
and dependents. Preliminary regulations state, "Being eligible for coverage
means having met the plan's substantive eligibility conditions, such as being
in an eligible job classification or achieving job-related licensure requirements
specified in the plan's terms." These regulations, issued back in March,
govern the 90-day waiting period issued jointly by all federal agencies
involved in enforcing ACA, and will be in effect through 2014.
The regulations make it clear you will not be considered in violation if, for
example, you have a 30-day waiting period (or a waiting period less than the
maximum of 90 days), but your employee takes longer than 30 days to elect
coverage under your plan. Also, if you hire a new employee who will be
working on a variable hour schedule and it's not yet clear if the employee will
average enough hours to be considered a full-timer, you can use "a
measurement period consistent with the timeframe permitted" under a
section of the law described here.
www.hrp.net
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