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Anthem. lijl
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Health care reform timeline
A year-by-year look at what to expect



 2010                     o    Early Retiree Reinsurance Program began
                          o    Began closing the Medicare Part D "donut hole"

                          o   Dependent coverage for adult children up to age 26 (or higher if state law mandates it)
                          o   No lifetime dollar limits on benefits
                          o   Restricted annual dollar limits on essential health benefits
                          o   No pre-existing condition exclusions for children
                          o   100% coverage for preventive services in network*
                          o   No prior authorization for emergency services or higher cost-sharing for out-of-network emergency
                              services*
                          o   No referrals required for OB/GYN services
                          o   Any available primary care physician (PCP) accepting new patients may be selected
                          o   Pediatrician may be selected as a PCP for children
                          o   Revised appeals process and changes to adverse benefit determinations (enforcement of some
                              regulations delayed until detailed guidance is issued)*
                          o   No discrimination in favor of highly compensated employees (enforcement delayed until detailed
                              guidance is issued)*

 2011                     o   Prescription required for health account reimbursement for over-the-counter medications
                          o   20% tax for nonqualified HSA withdrawals
                          o   Medical loss ratio standards go into effect(85% for large group)

                          o   Uniform summary of benefits and coverage/60-day notice for material modifications (delayed until final
                              regulations are issued)
                          o   Value of employer-sponsored coverage on W-2s for 2012 tax year- meaning W-2s issued in January
                              2013 (originally required earlier, but the IRS delayed the requirement until the 2012 tax year for large
                              employers and the 2013 tax year for employers who issue fewer than 250 W-2s)
                          o   First year medical Ioss ratio rebates may be issued
                          o   Employee notification of exchanges and premium subsidies
                          o   Medical flexible spending account contributions limited to $2,500 per year
                          o   Annual per-member fee for Patient-Centered Outcomes Research Institute (for fiscal year 2013, which
                              technically begins October 1, 2012)
                          o   Elimination of tax exclusion for Medicare Part D retiree drug subsidy payments
                          o   Penalties for employers who don't provide minimum coverage to full-time employees (50+ employees)
                          o   Employer requirement to auto-enroll employees into health benefits (200+ employees)
                          o   90-day limit on waiting periods for coverage
                          o   Small group redefined as 1-100 (states may defer until 2016)
                          o   No annual dollar limits on essential health benefits
                          o   Individual mandate
                          o   Guaranteed issue
                          o   30% incentive cap for wellness programs
                          o   Coverage of routine patient costs for clinical trials of life-threatening diseases*

 2018                     o   40% excise tax on high-cost "Cadillac" plans



*Not required for grandfathered group health plans
Benefit changes. Coverage requirements. Automatic
enrollment. When it comes to health care reform, there's
a lot to know- and a lot to do. The more you understand
the law and its provisions, the better you can prepare
for change and make strategic decisions that fit your
organization and your employees.


On the other hand, too much information can be
overwhelming. That's why this guide focuses only on the
key provisions that will affect you and the key decisions
you need to make. If you want more details, chat with your
broker or account representative or visit our website at
anthem.com/healthcarereform.




Moving reform forward for the benefit of you and your employees

To minimize disruption for you and your employees, we aim to implement health care reform as quickly and
effectively as possible. While unresolved legal and legislative challenges have created uncertainty about the
future of health care reform, these challenges will not affect our current implementation efforts. We will continue
to implement reform in good faith for the benefit of our customers and members.



Exempted plans

The federal health care reform law will impact many types of plans, but there are exceptions. In general,
these plans are exempted from all or some provisions of health care reform:
  o   Retiree-only plans with no active employees
  o   HIPAA-excepted benefits (benefits that are not an integral part of a health plan, such as stand-alone dental and
      vision, life and disability plans)
  o   Short-term health insurance plans
  o   Medigap and Medicare Supplement plans
  o   Long-term care insurance
  o   Employee assistance plans
Looking back
Employers weigh the pros and cons of grandfathering
For many em players, the big decision in 2010 was whether to grandfather their benefit plans. Under the health care
reform law, plans that existed on or before March 23, 2010, and haven't made certain changes since then may be
considered grandfathered plans. Grandfathered plans may be exempt from some of the requirements ofthe health
care reform law.


Cost concerns versus benefit implications
So far we have seen muted market interest in retaining grandfathered status. Why? Many employers cited the complexities
of remaining grandfathered, as well as a perception that it would offer limited benefit to them. This reflects the difficulty of
health care reform for many employers: balancingtoday's cost concerns with tomorrow's potential benefit implications:

 Employers' reasons to not grandfather                                              Employers' reasons to stay grandfathered

   Now (2010-2013):                                                                   Now (2010-2013):
    o    More flexibility to manage immediate cost concerns                            o    Nat required to include some benefits, such as 100%
         through benefit buy-downs and changes to employer                                  coverage for in-network preventive care services*
         contribution levels                                                           o    Able to maintain plan designs that aren't allowed for
    o    Fewer administrative responsibilities such as notices                              nongrandfathered plans
         and mandatory language on plan documents
                                                                                      Later (2014 and beyond):
    o    Access to all of the additional benefits the health                           o    Nat limited to four benefit tiers, all of which must
         care reform law requires, such as 100% coverage for                                include essential health benefits (small groups only)
         in-network preventive care services*
                                                                                       o    Nat required to implement community rating
   Later (2014 and beyond):                                                                 requirements and restricted age-based rating factors
    o    To be determined                                                                   (small groups only)




Can you grandfather? Should you?
We continue to administer grandfathered plans upon the request of our customers who qualify. To help you decide whether
you're eligible to grandfather- and if grandfathering is the right decision for you -we've developed a simpie, interactive
online tool that offers customized feedback based on your input. Try out the tool at
a nthem.com/hea lthca rereform or talk to your account representative.




*While not all health care reform changes are recuiraJ in grandfatherm plans,in some cases our company has decidm to adopt healthcare reform provisions in both
grandfatherm and nongrandfatherm plans. According to the U.S. Department of Health and Human Servtces (HHSl, adoptton of these additional provisions has no impact
on the grandfathenng status of those plans. For specific beneftt plan impacts of health care reform,please refer to plan materials provided to you
Looking back                                                  women's services (including FDA-approved contraception
                                                              methods) wiII take effect at the first renewal on or after
How we implemented the first round of provisions              August 1, 2012.

Here's an overview of how we implemented some key
                                                              Patient protections*
provisions for group health plans in 2010. These
provisions went into effect for plan years beginning on       We decided to include these provisions in all plans, even
or after September 23, 2010:                                  though they aren't required for grandfathered plans.

Dependent coverage to age 2 6                                 Revised appeals process and adverse benefit
For many plans, we implemented this provision early           determinations*
to avoid a coverage gap for spring 2010 graduates.            We created a standard appeal process that complies with
Group plan members were given the opportunity to              health care reform for fully insured and self-insured
enroll dependents younger than 26 at their first open         groups. We have updated adverse benefit determinations
enrollment after September 23, 2010. We decided to            (including explanation of benefit forms) to comply with
cover dependents to age 26 for most vision and dental         this provision's notice requirements.
pia ns as well, even though the health care reform law
doesn't apply to these HIPAA-excepted benefits.               No discrimination in favor of highly
                                                              compensated employees*
No lifetime dollar limits/restricted annual dollar
limits on essential health benefits                           In December 2010, the government issued a notice
                                                              delaying enforcement of this provision until more
We removed lifetime dollar limits from plans where            guidance is available. It is the employer's or group's
required and gave individuals who may have previously         responsibility to ensure compliance with this
reached their lifetime maximum an opportunity to              provision.
re-enroll at the group's regular open enrollment. We
implemented the annual limits provision, removing             Early Retiree Reinsurance Program
annual benefit and plan dollar limits. In general, we are
not administering restricted annual limits on essential       Five billion dollars was set aside to help employers
health benefits (also known as transitional annual limits).   continue to provide coverage to certain retirees. We have
                                                              helped customers apply for these funds by supplying
No member cost share for in-network                           required reportingand information. Fundsforthis
                                                              temporary program had nearly run out by late 2011- just
preventive care*
                                                              18 months after the program began.
We expanded our standard preventive care list and
updated nongrandfathered plans to cover these services
with no member cost share. We also chose to include
this coverage in some grandfathered plans. An updated
preventive care list that includes expanded coverage for


*Not reqJIred for grandfatffired group ffialth plans
Where we are today                                               Medical loss ratios
Making gradual shifts from 2011 to 2013                          Health insurance issuers will report medical loss ratios (the
                                                                 percentage of premiums spent on medical care and quality
From 2011to 2013, reform focuses less on benefit
                                                                 improvement, as opposed to administrative expenses) to
changes and more on industry regulation and funding
                                                                 HHS on a calendar-year schedule. This reporting starts with
reform-related programs. Some key provisions you should
                                                                 calendar year 2011. Issuers that don't meet the minimum
be aware of:
                                                                 medical loss ratio (85% for large group) during the calendar
                                                                 year will need to pay rebates by August 1of the following
Spending account changes
                                                                 year. The first rebate payments, if any, must be made by
Starting January 1, 2011(regardless of plan year                 August 1, 2012. For group plans, these rebates will be sent
dates), prescriptions are required for spending account          to the group. The group can then distribute the rebate to
reimbursement of over-the-counter drugs other than insulin.      current subscribers or use it to reduce premiums.
Also on January 1, 2011, the penalty for nonqualified health
savings account distributions went up to 20%. Starting in        Comparative effectiveness research plan fees
2013, health care flexible spending account contributions
                                                                 For plan/policy years ending after September 30, 2012, and
will be limited to $2,500 per year. The limit will be adjusted
                                                                 before October 1, 2019, the plan issuer or sponsor wi II pay
for the cost of living every year.
                                                                 a fee to partially support the Patient-Centered Outcomes
                                                                 Research Institute. In the first year, the annual fee will be $1
Uniform summary of benefits and coverage/
                                                                 multiplied bytheaverage numberofcovered lives. lnthe
notice of material modification                                  second year, it will increase to $2 multiplied by the average
These rules were scheduled to take effect in March 2012,         number of covered lives.
but they've been delayed until final regulations are issued.
Plan summaries must have consistent contents and
                                                                 Notification requirements
formatting. For fully insured plans,the plan issuer must         Starting in 2013, employers will need to start telling
provide a compliant paper or electronic summary at certain       employees about health insu ranee exchanges and
times in the enrollment process. Also, the plan issuer must      premium subsidies.
provide 60-day notice for material modifications to plan
benefits.The notice requirement doesn't apply to renewals.

W-2 reporting                                                      What do you need to do?
                                                                     o   If you offer spending accounts, update your employee
Employers must start reporting the value of employer-                    benefit materials to reflect the new rules.
sponsored coverage on W-2 forms for the 2012 tax
                                                                     o   Make sure your payroll department or vendor is
year- meaning W-2s issued in January 2013. This will be                  prepared for W-2 reporting.
a new, separate entry on the W-2 form. This is a reporting
obligation only and does not change the current tax-free
nature of the benefit.
Where we are today                                                                        workers. Starting in 2017, states may permit large groups
                                                                                          to purchase coverage through an exchange.
Moving to a new health insurance market in 2014
                                                                                          Employers will also be able to purchase coverage outside
The most significant health care reform requirements                                      of the exchanges. Many states have already started
start in 2014. These are some of the key requirements                                     setting up their exchanges. During this process, we're
that will affect employers:                                                               encouraging policymakers to design exchange policies
                                                                                          that maximize product choice inside the exchange and
Employer responsibility to provide coverage                                               minimize disruptions to the existing marketplace.

Employers with 50 or more full-time employees must offer
                                                                                          Employer reporting requirements
minimum coverage to active employees (see sidebar).
Employers will be subject to penalties if they don't                                      Employers will be required to report certain information
provide minimum coverage to full-time employees or if                                     to the IRS annually. This information includes:
they provide coverage that is not "affordable." These                                         o   Whether minimum coverage is offered to full-time
penalties will range from $2,000 to $3,000 per employee.                                          employees
                                                                                              o   Any waiting periods for health coverage
Automatic enrollment                                                                          o   The monthly premium for the lowestcostoption in
                                                                                                  each enrollment category under the plan
Employers with more than 200 employees must
                                                                                              o   The employer's share of the total allowed cost of
automatically enroll new and existing full-time employees
                                                                                                  benefits provided under the plan
in health insurance plans. Employees may opt out.
                                                                                              o   Number of full-time employees during each month

Health insurance exchanges                                                                    o   Name, address and taxpayer identification number (or
                                                                                                  Social Security number) of each full-time employee,
Starting in 2014, people who don't get health insu ranee at                                       and the months each employee was covered under the
                                                                                                  employer's plan
work may be able to shop for it through an exchange run
                                                                                              o   Other information that HHS may require (which will
by the state or the federal government. Small businesses
                                                                                                  likely be refined in later regulations)
also can use exchanges to find insurance for their


Requirements for minimum coverage
To be considered minimum coverage, a plan must:
o    Provide 60o/o actuarial value minimum- basically, this means the plan covers at least 60o/o of covered health care costs.
o    Be "affordable" based on regulations.

Note: Benefit package requirements are not defined;current guidance does not indicate that large group and self-insured
plans will need to include the essential health benefits package.

Requirements for exchange plans                                                                                                      Gold
To be offered in an exchange, a plan must:
o    Include the essential health benefits package.
o    Provide 60o/o actuarial value minimum.
                                                                                                              Silver
o    Comply with one of the four benefittiers with specified                                                  70%
     actuarial values (shown on the right).                                                                actuari al value


 Plus catastrophic plan offerings for 1nd1vt dual s who are younger than 30 or qualify oocause of financial hardship
What services are considered essential health benefits?
FAQs
Answering common questions about health care reform                Late in 2011, HHS released a bulletin on its approach for
                                                                   essential health benefits. Instead of defining a specific
                                                                   package or rules, HHS will let states choose based on
                                                                   a benchmark plan. If a state chooses not to select a
Can we increase our deductible a little bit each year and
                                                                   benchmark, HHS suggests that the defauIt benchmark will
stay grandfathered?
                                                                   be the small group plan with the largest enrollment in the
A small increase every year could cause a loss of                  state.
grandfathered status. That's because grandfathered status
                                                                   We do know that essential health benefits include at least
is determined by comparing benefits and contributions to
                                                                   these general categories:
the baseline plan in place on March 23, 2010, not the plan in
                                                                     o   Ambulatory patient services
place during the previous plan year. For more details about
                                                                     o   Emergency services
changes that would cause a loss of grandfathered status,
visit ourwebsite at a nthem.co m/healthcarereform. You               o   Hospitalization

can also discuss your unique situation with your account             o   Maternity and newborn care

representative.                                                      o   Mental health and substance use disorder services,
                                                                         including behavioral health treatment
If we make a benefit change that causes us to lose                   o   Prescription drugs
grandfathered status, when do we need to move to a                   o   Rehabilitative and habilitative services and devices
nongrandfathered plan?                                               o   Laboratory services
                                                                     o   Preventive and wellness services
If you make a benefit change that causes a loss of
grandfathered status,you would need to move to a                     o   Chronic disease management

nongrandfathered plan immediately.                                   o   Pediatric services, including oral and vision care


What preventive care services were added for                       Does the health care reform law require health plans to
nongrandfathered plans?                                            cover members' costs for clinical trials?

Most of the services required by HHS were already included         Starting in 2014, nongrandfathered plans must include
in our preventive care guidelines; however, we did make            coverage of routine patient costs for clinical trials of
some modifications:                                                life-threatening diseases.
  o   We added certain services, including several additional
      screening tests and certain services associated with
      previously covered screenings and vaccines.
  o   We added counseling related to aspirin use, tobacco
      cessation, obesity and alcohol.

  o   Some services currently covered as medical/maternity are
      now considered preventive and covered with no cost share
      applied.
 An updated preventive care list that includes expanded
 coverage for women's services (including FDA-approved
 contraception methods) will take effect at the first renewal on
 orafterAugust1 2012.
                ,
How does a fully insured plan determine whether it is
complying with nondiscrimination tests?
We recommend that the group work with its legal and
benefits counselors as we cannot provide legal or tax
advice. The health care reform law states that the rules
for determining compliance for fully insured pla ns are
similar to the rules that apply for self-insured plans.
These rules are outlined in Internal Revenue Code
Section 105. In December 2010, the government issued a
notice delaying enforcement ofthis provision until more
guidance is issued.

Can an employer impose an eligibility waiting period
before enrolling new employees?
Yes,to the extent that the federal health care reform law
and state law permits. Starting in 2014, under the federal
health care reform law eligibility waiting periods cannot
exceed 90 days.
                                                             Find more questions and answers on
Does the employer mandate provision require                  our website
employers to offer dependent coverage?                       We're constantly adding new health care
                                                             reform resources to our website, including
No, dependents do not have to be offered coverage based      answers to common questions. If you have a
on the employer mandate.                                     question about health care reform that isn't
                                                             answered here, be sure to visit anthem.com/
What is considered a "Cadillac plan"?                        healthcarereform.

The health care reform law defines high-cost coverage
(also known as a "Cadillac plan") as a plan that costs
more than $10,200 (multiplied by the health cost
adjustment percentage) for single coverage or $2 7,500
(multiplied by the health cost adjustment percentage)
for family coverage. The health care reform law imposes
a 40% excise tax on these plans starting in 2018. The
insurer or employer will be responsible for the tax. The
amounts will increase in future years based on factors
that will be provided to the insurer or employer.
Summary
Pulling it all together




 Prov1s1on                                                              Requ1red for grandfathered plans               Requ1red for nongrandfathered plans


 No Iifetime benefit dollar limits

 Dependent coverage for adult children up to age
 26 (or higher if state law mandates it)
 No annual dollar Iim its on certain types of
 benefits for group plans

 100% coverage for preventive care in-network                                                 *
 No prior authorization for emergency services or
 higher cost sharing for out-of-network emergency                                             *
 services
 No pre-existing limitations for children under the
 age of 19 for group plans

 No discrimination in favor of highly compensated
 employees

 Revised appeals process and changes to adverse
 benefit determinations                                                                       *
 Reporting the value of employer-sponsored
 coverage on W-2s (2012 tax year)

 Uniform explanation of coverage (2012)

 Pre-enrollment document sent explaining
 benefits and exclusions (2012)

 60-day notice for material modifications to plan
 benefits (2012)

 90-day I im it on waiting periods for coverage
 (2014)

 Penalties for 50+ employers who don't provide
 minimum coverage to full-time employees (2014)

 Automatic enrollment in health plan for
 employers with 200+ employees (2014)

 Coverage of routine patient costs for clinical
 trials of life-threatening diseases (2014)


*In some cases   OJ   r company has decided to adopt trese realth care reform prov1 s1ons1n both grandfatherec and nongrandfatrerec plans
What do you need to do?
 o   Visit our health care reform website for details about maintaining grandfathered status.
 o   Update spending account materials to reflect new rules.
 o   Prepare for W-2 reporting for the 2012 tax year.

 Need help making decisions in the complex post-health care reform environment?
 We've developed tools to make health care reform information more understandable and customized.
 Check out our comprehensive online resource for up-to-th inute information and tools:
 o   Articles and fact sheets summarize the regulations and answer common questions.
 o   User-friendly layout makes it easy to find the information you need.

 It's all at anthem.com/healthcarereform.
Anthem. U
  BlueCross BlueShield




This coo tent is provided solely for informatiooalpurposes It is not intended as and does not constitute legaladvice. The informa tioo contained herein should not be relied upon or used as a slilstitute for consulta tioo with
legal,accountirg, tax and/or other professionaladvisers

lvlthem Ellue Cross andEllue Sh1eld IS the trade name of: In Colorado:Rocky Mountain Hospital and Med1cal serv1ce. Inc HMO products mderwr ttenby HMO Colorado. Inc InConrect1cut: Anthem HealthPlans. Inc InIndi-
ana Anthem Insurance compan1es.Ire InKentucky Anthem Health Plans of Kentuc ky, Inc In Ma1re· Anthem Health Plans of Ma1re. Inc InMISsour(excluding 30 count1es 1n the Kansas C1 ty area) R1ghtCHOICE® Managed
Care.Inc (RITl. Healthy Alliance® Life Insurance Company (HALIC). and HMO M1ssour. Inc RIT and certa1n a ffiliates adminiSter noo-HMO benef1ts underwritten by HALIC and HMO benefits underwritten by HMO M1ssour .
Inc RIT and certam affilia tes mly prov1de adminiS trative serv1ces for self-funded plans and do no t mderwrte benefitS In Ne vada Rocky Momta1nHospital and Med1cal serv1ce. Inc HMO products underwritten by HMO
Colorado. Ire . dba HMO Nevada In New Hampsh;re: Anthem HealthPlans of New Hampsh re.Ire In Oh1o:Community Insurance Company In V1rg                         1n1a: Anthem Health Plans of V1rg1n1a. Inc trades as Anthem Ellue Cross
and Ellue Sh1ed 1n V1rg1n1a. and 1ts serv1ce area IS all of V1rg1n1a except for the City of Fa;rfax. the Town of V1enna. and the area eas t o f State Route 123 In W1scooS1n: Ellue Cross Ellue Sh1ed of W1Scoos1n (ElCElSWI), wh1ch
              l                                                                                                                                                                                      l
underwrtes or admniSte rs the PPO and 1ndemn1ty polic1es: Compcare Health serv1ces Insurance Corpora tiOn (Compcare).wh1ch underwrites or adm1n1s ters the HMO polic1es: and Compcare and ElCElSW1 collectively,
                    i
wh1chunderwrite or adm1n1s ter the POS polic1es Independent licensees o f the Ellue Cross and Ellue Sh1eld Assoc1at1on ® ANTHEM IS a regiStered trademark o f lvlthem Insurance Compan1es. Inc The Ellue Cross and Ellue
Sh1eld names and symbols are reg1s tered marks of the Ellue Cross andEllue Sh1eld Assoc1at1on

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Anthem Large Employer Ppaca Time Line 10 2012

  • 1. Anthem. lijl Y. -...c.- B1v'CIHdd '201167AHEEHAB&FI 111 FOOlUii'Z '2
  • 2. Health care reform timeline A year-by-year look at what to expect 2010 o Early Retiree Reinsurance Program began o Began closing the Medicare Part D "donut hole" o Dependent coverage for adult children up to age 26 (or higher if state law mandates it) o No lifetime dollar limits on benefits o Restricted annual dollar limits on essential health benefits o No pre-existing condition exclusions for children o 100% coverage for preventive services in network* o No prior authorization for emergency services or higher cost-sharing for out-of-network emergency services* o No referrals required for OB/GYN services o Any available primary care physician (PCP) accepting new patients may be selected o Pediatrician may be selected as a PCP for children o Revised appeals process and changes to adverse benefit determinations (enforcement of some regulations delayed until detailed guidance is issued)* o No discrimination in favor of highly compensated employees (enforcement delayed until detailed guidance is issued)* 2011 o Prescription required for health account reimbursement for over-the-counter medications o 20% tax for nonqualified HSA withdrawals o Medical loss ratio standards go into effect(85% for large group) o Uniform summary of benefits and coverage/60-day notice for material modifications (delayed until final regulations are issued) o Value of employer-sponsored coverage on W-2s for 2012 tax year- meaning W-2s issued in January 2013 (originally required earlier, but the IRS delayed the requirement until the 2012 tax year for large employers and the 2013 tax year for employers who issue fewer than 250 W-2s) o First year medical Ioss ratio rebates may be issued o Employee notification of exchanges and premium subsidies o Medical flexible spending account contributions limited to $2,500 per year o Annual per-member fee for Patient-Centered Outcomes Research Institute (for fiscal year 2013, which technically begins October 1, 2012) o Elimination of tax exclusion for Medicare Part D retiree drug subsidy payments o Penalties for employers who don't provide minimum coverage to full-time employees (50+ employees) o Employer requirement to auto-enroll employees into health benefits (200+ employees) o 90-day limit on waiting periods for coverage o Small group redefined as 1-100 (states may defer until 2016) o No annual dollar limits on essential health benefits o Individual mandate o Guaranteed issue o 30% incentive cap for wellness programs o Coverage of routine patient costs for clinical trials of life-threatening diseases* 2018 o 40% excise tax on high-cost "Cadillac" plans *Not required for grandfathered group health plans
  • 3. Benefit changes. Coverage requirements. Automatic enrollment. When it comes to health care reform, there's a lot to know- and a lot to do. The more you understand the law and its provisions, the better you can prepare for change and make strategic decisions that fit your organization and your employees. On the other hand, too much information can be overwhelming. That's why this guide focuses only on the key provisions that will affect you and the key decisions you need to make. If you want more details, chat with your broker or account representative or visit our website at anthem.com/healthcarereform. Moving reform forward for the benefit of you and your employees To minimize disruption for you and your employees, we aim to implement health care reform as quickly and effectively as possible. While unresolved legal and legislative challenges have created uncertainty about the future of health care reform, these challenges will not affect our current implementation efforts. We will continue to implement reform in good faith for the benefit of our customers and members. Exempted plans The federal health care reform law will impact many types of plans, but there are exceptions. In general, these plans are exempted from all or some provisions of health care reform: o Retiree-only plans with no active employees o HIPAA-excepted benefits (benefits that are not an integral part of a health plan, such as stand-alone dental and vision, life and disability plans) o Short-term health insurance plans o Medigap and Medicare Supplement plans o Long-term care insurance o Employee assistance plans
  • 4. Looking back Employers weigh the pros and cons of grandfathering For many em players, the big decision in 2010 was whether to grandfather their benefit plans. Under the health care reform law, plans that existed on or before March 23, 2010, and haven't made certain changes since then may be considered grandfathered plans. Grandfathered plans may be exempt from some of the requirements ofthe health care reform law. Cost concerns versus benefit implications So far we have seen muted market interest in retaining grandfathered status. Why? Many employers cited the complexities of remaining grandfathered, as well as a perception that it would offer limited benefit to them. This reflects the difficulty of health care reform for many employers: balancingtoday's cost concerns with tomorrow's potential benefit implications: Employers' reasons to not grandfather Employers' reasons to stay grandfathered Now (2010-2013): Now (2010-2013): o More flexibility to manage immediate cost concerns o Nat required to include some benefits, such as 100% through benefit buy-downs and changes to employer coverage for in-network preventive care services* contribution levels o Able to maintain plan designs that aren't allowed for o Fewer administrative responsibilities such as notices nongrandfathered plans and mandatory language on plan documents Later (2014 and beyond): o Access to all of the additional benefits the health o Nat limited to four benefit tiers, all of which must care reform law requires, such as 100% coverage for include essential health benefits (small groups only) in-network preventive care services* o Nat required to implement community rating Later (2014 and beyond): requirements and restricted age-based rating factors o To be determined (small groups only) Can you grandfather? Should you? We continue to administer grandfathered plans upon the request of our customers who qualify. To help you decide whether you're eligible to grandfather- and if grandfathering is the right decision for you -we've developed a simpie, interactive online tool that offers customized feedback based on your input. Try out the tool at a nthem.com/hea lthca rereform or talk to your account representative. *While not all health care reform changes are recuiraJ in grandfatherm plans,in some cases our company has decidm to adopt healthcare reform provisions in both grandfatherm and nongrandfatherm plans. According to the U.S. Department of Health and Human Servtces (HHSl, adoptton of these additional provisions has no impact on the grandfathenng status of those plans. For specific beneftt plan impacts of health care reform,please refer to plan materials provided to you
  • 5. Looking back women's services (including FDA-approved contraception methods) wiII take effect at the first renewal on or after How we implemented the first round of provisions August 1, 2012. Here's an overview of how we implemented some key Patient protections* provisions for group health plans in 2010. These provisions went into effect for plan years beginning on We decided to include these provisions in all plans, even or after September 23, 2010: though they aren't required for grandfathered plans. Dependent coverage to age 2 6 Revised appeals process and adverse benefit For many plans, we implemented this provision early determinations* to avoid a coverage gap for spring 2010 graduates. We created a standard appeal process that complies with Group plan members were given the opportunity to health care reform for fully insured and self-insured enroll dependents younger than 26 at their first open groups. We have updated adverse benefit determinations enrollment after September 23, 2010. We decided to (including explanation of benefit forms) to comply with cover dependents to age 26 for most vision and dental this provision's notice requirements. pia ns as well, even though the health care reform law doesn't apply to these HIPAA-excepted benefits. No discrimination in favor of highly compensated employees* No lifetime dollar limits/restricted annual dollar limits on essential health benefits In December 2010, the government issued a notice delaying enforcement of this provision until more We removed lifetime dollar limits from plans where guidance is available. It is the employer's or group's required and gave individuals who may have previously responsibility to ensure compliance with this reached their lifetime maximum an opportunity to provision. re-enroll at the group's regular open enrollment. We implemented the annual limits provision, removing Early Retiree Reinsurance Program annual benefit and plan dollar limits. In general, we are not administering restricted annual limits on essential Five billion dollars was set aside to help employers health benefits (also known as transitional annual limits). continue to provide coverage to certain retirees. We have helped customers apply for these funds by supplying No member cost share for in-network required reportingand information. Fundsforthis temporary program had nearly run out by late 2011- just preventive care* 18 months after the program began. We expanded our standard preventive care list and updated nongrandfathered plans to cover these services with no member cost share. We also chose to include this coverage in some grandfathered plans. An updated preventive care list that includes expanded coverage for *Not reqJIred for grandfatffired group ffialth plans
  • 6. Where we are today Medical loss ratios Making gradual shifts from 2011 to 2013 Health insurance issuers will report medical loss ratios (the percentage of premiums spent on medical care and quality From 2011to 2013, reform focuses less on benefit improvement, as opposed to administrative expenses) to changes and more on industry regulation and funding HHS on a calendar-year schedule. This reporting starts with reform-related programs. Some key provisions you should calendar year 2011. Issuers that don't meet the minimum be aware of: medical loss ratio (85% for large group) during the calendar year will need to pay rebates by August 1of the following Spending account changes year. The first rebate payments, if any, must be made by Starting January 1, 2011(regardless of plan year August 1, 2012. For group plans, these rebates will be sent dates), prescriptions are required for spending account to the group. The group can then distribute the rebate to reimbursement of over-the-counter drugs other than insulin. current subscribers or use it to reduce premiums. Also on January 1, 2011, the penalty for nonqualified health savings account distributions went up to 20%. Starting in Comparative effectiveness research plan fees 2013, health care flexible spending account contributions For plan/policy years ending after September 30, 2012, and will be limited to $2,500 per year. The limit will be adjusted before October 1, 2019, the plan issuer or sponsor wi II pay for the cost of living every year. a fee to partially support the Patient-Centered Outcomes Research Institute. In the first year, the annual fee will be $1 Uniform summary of benefits and coverage/ multiplied bytheaverage numberofcovered lives. lnthe notice of material modification second year, it will increase to $2 multiplied by the average These rules were scheduled to take effect in March 2012, number of covered lives. but they've been delayed until final regulations are issued. Plan summaries must have consistent contents and Notification requirements formatting. For fully insured plans,the plan issuer must Starting in 2013, employers will need to start telling provide a compliant paper or electronic summary at certain employees about health insu ranee exchanges and times in the enrollment process. Also, the plan issuer must premium subsidies. provide 60-day notice for material modifications to plan benefits.The notice requirement doesn't apply to renewals. W-2 reporting What do you need to do? o If you offer spending accounts, update your employee Employers must start reporting the value of employer- benefit materials to reflect the new rules. sponsored coverage on W-2 forms for the 2012 tax o Make sure your payroll department or vendor is year- meaning W-2s issued in January 2013. This will be prepared for W-2 reporting. a new, separate entry on the W-2 form. This is a reporting obligation only and does not change the current tax-free nature of the benefit.
  • 7. Where we are today workers. Starting in 2017, states may permit large groups to purchase coverage through an exchange. Moving to a new health insurance market in 2014 Employers will also be able to purchase coverage outside The most significant health care reform requirements of the exchanges. Many states have already started start in 2014. These are some of the key requirements setting up their exchanges. During this process, we're that will affect employers: encouraging policymakers to design exchange policies that maximize product choice inside the exchange and Employer responsibility to provide coverage minimize disruptions to the existing marketplace. Employers with 50 or more full-time employees must offer Employer reporting requirements minimum coverage to active employees (see sidebar). Employers will be subject to penalties if they don't Employers will be required to report certain information provide minimum coverage to full-time employees or if to the IRS annually. This information includes: they provide coverage that is not "affordable." These o Whether minimum coverage is offered to full-time penalties will range from $2,000 to $3,000 per employee. employees o Any waiting periods for health coverage Automatic enrollment o The monthly premium for the lowestcostoption in each enrollment category under the plan Employers with more than 200 employees must o The employer's share of the total allowed cost of automatically enroll new and existing full-time employees benefits provided under the plan in health insurance plans. Employees may opt out. o Number of full-time employees during each month Health insurance exchanges o Name, address and taxpayer identification number (or Social Security number) of each full-time employee, Starting in 2014, people who don't get health insu ranee at and the months each employee was covered under the employer's plan work may be able to shop for it through an exchange run o Other information that HHS may require (which will by the state or the federal government. Small businesses likely be refined in later regulations) also can use exchanges to find insurance for their Requirements for minimum coverage To be considered minimum coverage, a plan must: o Provide 60o/o actuarial value minimum- basically, this means the plan covers at least 60o/o of covered health care costs. o Be "affordable" based on regulations. Note: Benefit package requirements are not defined;current guidance does not indicate that large group and self-insured plans will need to include the essential health benefits package. Requirements for exchange plans Gold To be offered in an exchange, a plan must: o Include the essential health benefits package. o Provide 60o/o actuarial value minimum. Silver o Comply with one of the four benefittiers with specified 70% actuarial values (shown on the right). actuari al value Plus catastrophic plan offerings for 1nd1vt dual s who are younger than 30 or qualify oocause of financial hardship
  • 8. What services are considered essential health benefits? FAQs Answering common questions about health care reform Late in 2011, HHS released a bulletin on its approach for essential health benefits. Instead of defining a specific package or rules, HHS will let states choose based on a benchmark plan. If a state chooses not to select a Can we increase our deductible a little bit each year and benchmark, HHS suggests that the defauIt benchmark will stay grandfathered? be the small group plan with the largest enrollment in the A small increase every year could cause a loss of state. grandfathered status. That's because grandfathered status We do know that essential health benefits include at least is determined by comparing benefits and contributions to these general categories: the baseline plan in place on March 23, 2010, not the plan in o Ambulatory patient services place during the previous plan year. For more details about o Emergency services changes that would cause a loss of grandfathered status, visit ourwebsite at a nthem.co m/healthcarereform. You o Hospitalization can also discuss your unique situation with your account o Maternity and newborn care representative. o Mental health and substance use disorder services, including behavioral health treatment If we make a benefit change that causes us to lose o Prescription drugs grandfathered status, when do we need to move to a o Rehabilitative and habilitative services and devices nongrandfathered plan? o Laboratory services o Preventive and wellness services If you make a benefit change that causes a loss of grandfathered status,you would need to move to a o Chronic disease management nongrandfathered plan immediately. o Pediatric services, including oral and vision care What preventive care services were added for Does the health care reform law require health plans to nongrandfathered plans? cover members' costs for clinical trials? Most of the services required by HHS were already included Starting in 2014, nongrandfathered plans must include in our preventive care guidelines; however, we did make coverage of routine patient costs for clinical trials of some modifications: life-threatening diseases. o We added certain services, including several additional screening tests and certain services associated with previously covered screenings and vaccines. o We added counseling related to aspirin use, tobacco cessation, obesity and alcohol. o Some services currently covered as medical/maternity are now considered preventive and covered with no cost share applied. An updated preventive care list that includes expanded coverage for women's services (including FDA-approved contraception methods) will take effect at the first renewal on orafterAugust1 2012. ,
  • 9. How does a fully insured plan determine whether it is complying with nondiscrimination tests? We recommend that the group work with its legal and benefits counselors as we cannot provide legal or tax advice. The health care reform law states that the rules for determining compliance for fully insured pla ns are similar to the rules that apply for self-insured plans. These rules are outlined in Internal Revenue Code Section 105. In December 2010, the government issued a notice delaying enforcement ofthis provision until more guidance is issued. Can an employer impose an eligibility waiting period before enrolling new employees? Yes,to the extent that the federal health care reform law and state law permits. Starting in 2014, under the federal health care reform law eligibility waiting periods cannot exceed 90 days. Find more questions and answers on Does the employer mandate provision require our website employers to offer dependent coverage? We're constantly adding new health care reform resources to our website, including No, dependents do not have to be offered coverage based answers to common questions. If you have a on the employer mandate. question about health care reform that isn't answered here, be sure to visit anthem.com/ What is considered a "Cadillac plan"? healthcarereform. The health care reform law defines high-cost coverage (also known as a "Cadillac plan") as a plan that costs more than $10,200 (multiplied by the health cost adjustment percentage) for single coverage or $2 7,500 (multiplied by the health cost adjustment percentage) for family coverage. The health care reform law imposes a 40% excise tax on these plans starting in 2018. The insurer or employer will be responsible for the tax. The amounts will increase in future years based on factors that will be provided to the insurer or employer.
  • 10. Summary Pulling it all together Prov1s1on Requ1red for grandfathered plans Requ1red for nongrandfathered plans No Iifetime benefit dollar limits Dependent coverage for adult children up to age 26 (or higher if state law mandates it) No annual dollar Iim its on certain types of benefits for group plans 100% coverage for preventive care in-network * No prior authorization for emergency services or higher cost sharing for out-of-network emergency * services No pre-existing limitations for children under the age of 19 for group plans No discrimination in favor of highly compensated employees Revised appeals process and changes to adverse benefit determinations * Reporting the value of employer-sponsored coverage on W-2s (2012 tax year) Uniform explanation of coverage (2012) Pre-enrollment document sent explaining benefits and exclusions (2012) 60-day notice for material modifications to plan benefits (2012) 90-day I im it on waiting periods for coverage (2014) Penalties for 50+ employers who don't provide minimum coverage to full-time employees (2014) Automatic enrollment in health plan for employers with 200+ employees (2014) Coverage of routine patient costs for clinical trials of life-threatening diseases (2014) *In some cases OJ r company has decided to adopt trese realth care reform prov1 s1ons1n both grandfatherec and nongrandfatrerec plans
  • 11. What do you need to do? o Visit our health care reform website for details about maintaining grandfathered status. o Update spending account materials to reflect new rules. o Prepare for W-2 reporting for the 2012 tax year. Need help making decisions in the complex post-health care reform environment? We've developed tools to make health care reform information more understandable and customized. Check out our comprehensive online resource for up-to-th inute information and tools: o Articles and fact sheets summarize the regulations and answer common questions. o User-friendly layout makes it easy to find the information you need. It's all at anthem.com/healthcarereform.
  • 12. Anthem. U BlueCross BlueShield This coo tent is provided solely for informatiooalpurposes It is not intended as and does not constitute legaladvice. The informa tioo contained herein should not be relied upon or used as a slilstitute for consulta tioo with legal,accountirg, tax and/or other professionaladvisers lvlthem Ellue Cross andEllue Sh1eld IS the trade name of: In Colorado:Rocky Mountain Hospital and Med1cal serv1ce. Inc HMO products mderwr ttenby HMO Colorado. Inc InConrect1cut: Anthem HealthPlans. Inc InIndi- ana Anthem Insurance compan1es.Ire InKentucky Anthem Health Plans of Kentuc ky, Inc In Ma1re· Anthem Health Plans of Ma1re. Inc InMISsour(excluding 30 count1es 1n the Kansas C1 ty area) R1ghtCHOICE® Managed Care.Inc (RITl. Healthy Alliance® Life Insurance Company (HALIC). and HMO M1ssour. Inc RIT and certa1n a ffiliates adminiSter noo-HMO benef1ts underwritten by HALIC and HMO benefits underwritten by HMO M1ssour . Inc RIT and certam affilia tes mly prov1de adminiS trative serv1ces for self-funded plans and do no t mderwrte benefitS In Ne vada Rocky Momta1nHospital and Med1cal serv1ce. Inc HMO products underwritten by HMO Colorado. Ire . dba HMO Nevada In New Hampsh;re: Anthem HealthPlans of New Hampsh re.Ire In Oh1o:Community Insurance Company In V1rg 1n1a: Anthem Health Plans of V1rg1n1a. Inc trades as Anthem Ellue Cross and Ellue Sh1ed 1n V1rg1n1a. and 1ts serv1ce area IS all of V1rg1n1a except for the City of Fa;rfax. the Town of V1enna. and the area eas t o f State Route 123 In W1scooS1n: Ellue Cross Ellue Sh1ed of W1Scoos1n (ElCElSWI), wh1ch l l underwrtes or admniSte rs the PPO and 1ndemn1ty polic1es: Compcare Health serv1ces Insurance Corpora tiOn (Compcare).wh1ch underwrites or adm1n1s ters the HMO polic1es: and Compcare and ElCElSW1 collectively, i wh1chunderwrite or adm1n1s ter the POS polic1es Independent licensees o f the Ellue Cross and Ellue Sh1eld Assoc1at1on ® ANTHEM IS a regiStered trademark o f lvlthem Insurance Compan1es. Inc The Ellue Cross and Ellue Sh1eld names and symbols are reg1s tered marks of the Ellue Cross andEllue Sh1eld Assoc1at1on