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Employer Deadline Approaching: Medicare Part D Notices

October 7, 2019

Employer Deadline Approaching: Medicare Part D Notices

Each year, Medicare Part D requires group health plan sponsors to disclose to individuals who are eligible for Medicare Part D and to the Centers for Medicare and Medicaid Services (CMS) whether the health plan’s prescription drug coverage is creditable. Plan sponsors must provide the annual disclosure notice to Medicare-eligible individuals before Oct. 15, 2019.


What is this notice?

This notice is important because Medicare beneficiaries who are not covered by creditable prescription drug coverage and do not enroll in Medicare Part D when first eligible will likely pay higher premiums if they enroll at a later date. Although there are no specific penalties associated with this notice requirement, failing to provide the notice may be detrimental to employees.


What do employers need to do?

Employers should confirm whether their health plans’ prescription drug coverage is creditable or non-creditable and prepare to send their Medicare Part D disclosure notices before Oct. 15, 2019. To make the process easier, employers often include Medicare Part D notices in open enrollment packets.



CMS has provided model disclosure notices for employers to use. Employers are not required to use the model notices from CMS. However, if the model language is not used, a plan sponsor’s notices must include certain information, including a disclosure about whether the plan’s coverage is creditable and explanations of the meaning of creditable coverage and why creditable coverage is important.


Contact Consociate Health to learn more about these employer requirements.

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Hospitals To Publish Retail Prices Under A New Proposed Rule

September 4, 2019

In July, the Centers for Medicare and Medicaid (CMS) proposed rules that would require all Medicare-participating hospitals to post their negotiated prices for standard health care services.

The proposed rule is intended to increase pricing transparency and help consumers understand the charges they may incur before receiving care.

These are just proposed rules at the moment, which means no changes will be made effective until the rules are finalized. The agency is currently asking for comments on the proposed rule. The deadline for submitting comments is Sept. 27, 2019.

We will continue to monitor and keep you updated on these developments.

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Open Enrollment: What’s Changing in 2020?

To prepare for open enrollment, group health plan sponsors should be aware of the legal changes affecting the design and administration of their plans for plan years beginning on or after Jan. 1, 2020. Employers should review their plan documents to confirm that they include these required changes.

In addition, any changes to a health plan’s benefits for the 2020 plan year should be communicated to plan participants through an updated summary plan description (SPD) or a summary of material modifications (SMM).

Health plan sponsors should also confirm that their open enrollment materials contain certain required participant notices, when applicable—for example, the summary of benefits and coverage (SBC). There are also some participant notices that must be provided annually or upon initial enrollment.

Important Notices

  • Annual CHIP notice
  • Medicare Part D creditable coverage notice
  • Notice of grandfathered status (if applicable)
  • Annual notice regarding coverage requirements for mastectomy-related benefits (WHCRA notice)

Don’t wait any longer to review your plans. Contact Consociate Health for a full list of 2020 plan changes and requirements.

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Celebrating 9 Years With AIMM

August 15, 2019

This week, Consociate Health celebrates our 9-year anniversary with Ault International Medical Management.

Thank you Nurse Deb Ault and Chris Ault for a productive day planning our future to disrupt the industry, not the employees.

We are grateful for this impactful strategic partnership with AIMM that has delivered impressive ROI results, and look forward to what it will bring to both of our organizations in the next 9 years.

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Final Rule Expands Options For HRAs

August 5, 2019

Health officials issued a final rule that expands the usability of health reimbursement arrangements (HRAs).

Effective in 2020, the final rule establishes two new types of HRAs:

Individual Coverage HRA: Allows employers to offer an HRA to be used to reimburse the cost of individual market premiums on a tax-preferred basis, subject to certain conditions, as an alternative to traditional group health plan coverage.

Excepted Benefits HRA: Allows employers that offer traditional group coverage to provide an HRA of up to $1,800 per year (as adjusted) to reimburse certain qualified medical expenses.

Talk to us to learn more about the specifics of these new plan designs.

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Executive Order On Health Costs To Affect Employer Health Plans

President Donald Trump recently signed an executive order aimed at improving price and quality transparency in health care. The order is intended to increase availability of health care price and quality information and protect patients from surprise medical bills.

What’s in the Order?

Specifically, the order is aimed at:

  • Eliminating unnecessary barriers to price and quality transparency
  • Increasing the availability of meaningful price and quality information for patients
  • Enhancing patients’ control over their own health care resources, including through tax-preferred medical accounts
  • Protecting patients from surprise medical bills

Employer Impact

Within 120 days, the order directs the Treasury to issue guidance to expand access to high-deductible health plans.

Additionally, the order directs the Treasury to propose regulations within 180 days to:

  • Treat expenses related to certain types of arrangements—potentially including direct primary care arrangements and health care sharing ministries—as eligible medical expenses
  • Increase the amount of funds that can carry over without penalty at the end of the year for flexible spending accounts

To learn more about how this order might affect you, speak with us today.

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2020 HSA/HDHP Limits Announced

July 19, 2019

The IRS recently announced that limits for health savings account (HSA) contributions will increase for 2019. The high deductible health plan (HDHP) maximum out-of-pocket limits will also increase for 2020. The HSA contribution limits will increase effective Jan. 1, 2020, while the HDHP limits will increase effective for plan years beginning on or after Jan. 1, 2020.

These limits vary based on whether an individual has self-only or family coverage under an HDHP.

Because the cost-sharing limits for HDHPs will change for 2020, employers that sponsor these plans may need to make plan design changes for plan years beginning in 2020.

Also, if an employer communicates the HSA contribution limits to employees as part of the enrollment process, these enrollment materials should be updated to reflect the increased limits that apply for 2020.

New Limits
The following chart shows the HSA and HDHP limits for 2020 as compared to 2019. It also includes the catch-up contribution limit that applies to HSA-eligible individuals who are age 55 or older, which is not adjusted for inflation and stays the same from year to year.

2020 HSA Contribution Limit
• Family – $7,100 (up $100)
• Self-only – $3,550 (up $50)

2020 HSA Catch-up Contributions
• Age 55+ – $1,000 (no change)

2020 HDHP Minimum Deductible
• Family – $2,800 (up $100)
• Self-only – $1,400 (up $50)

2020 HDHP Maximum Out-of-pocket Expense Limit
(Deductibles, copayments and other amounts, but not premiums)
• Family – $13,800 (up $300)
• Self-only – $6,900 (up $150)

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Moves Toward Better Health Care Price Transparency

July 8, 2019

Beginning in May 2018, the Trump administration began searching for ways to curb out-of-control prescription drug costs—referring to the initiative as American Patients First. This effort is finally seeing some traction, with the administration issuing regulations aimed at improving health care pricing transparency in May 2019.

Drug Pricing Transparency 
Drug companies will now be “required to disclose to patients the list price for prescription drugs in TV ads,” according to the Department of Health and Human Services (HHS).

More specifically, the rule requires prescriptions covered by Medicare or Medicaid that cost $35 or more per month for a typical course of therapy to be disclosed. Drugs under that threshold are unaffected.

HHS points out that the 10 most commonly advertised drugs range in price from several hundred to several thousands of dollars for a typical month of treatment.

This rule will take effect July 9, 2019. Employers should prepare for increased employee questions regarding drug costs.

President Trump’s Plan to Combat Surprise Medical Billing 
On May 9, 2019, President Donald Trump delivered a speech criticizing the practice of surprise medical billing. He announced a general plan of attack and hinted at a few specifics for curbing the trend. Here are the four main regulatory aspects called out by the president, suggesting that they might be tackled first:

  1. In emergency situations, patients shouldn’t have to “bear the burden” of out-of-network costs.
  2. Balanced billing should be prohibited for emergency care.
  3. For scheduled non-emergency care, patients should receive an “honest” bill up front—including an itemized list of out-of-pocket expenses the patient must cover.
  4. Patients should not receive a surprise bill from out-of-network providers they did not choose themselves.

Lower Health Care Costs Act 
Just a few weeks after the president’s speech on combatting surprise medical billing, the Senate Health Committee proposed a bipartisan bill called the Lower Health Care Costs Act.

The Lower Health Care Costs Act has five main components, including:

  1. Addressing surprise medical bills
  2. Lowering the cost of prescription drugs
  3. Improving transparency
  4. Improving public health
  5. Improving the exchange of health information

The Senate Health Committee Chairman Sen. Lamar Alexander said that “Republicans and Democrats in the United States Senate have announced this proposal of nearly three dozen specific bipartisan provisions that will reduce the cost of what Americans pay for health care. These are common sense steps we can take, and every single one of them has the objective of reducing the health care costs that you pay for out of your own pocket.”

The proposed legislation also includes a provision that would require benefits brokers to disclose their fees and any incentives they may receive from insurers. This provision would create a new level of transparency between employers and their benefits brokers, as many employers aren’t aware of the inner workings of health plan agreements or renewals.

What’s Next? 
The Lower Health Care Costs Act is just proposed legislation at the moment, meaning that there are no compliance obligations to meet. However, Sen. Lamar Alexander, bill co-sponsor, hopes that the bill will be on the Senate floor for a vote by July of this year.

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Consociate Health Recognized by WEX Inc. for Outstanding Achievements

July 3, 2019

Earns Evangelism Award

Decatur, Illinois — Consociate Health has been honored by WEX Inc. with a 2018 Partner Excellence Award for outstanding business achievements. Consociate Health received the Excellence Award for Evangelism at WEX SPARK Health 2019, the annual WEX Health Partner gathering held recently in Miami Beach, Florida.

Consociate Health was selected for the award because of its accomplishments in developing and delivering innovative and creative concepts that produce robust card growth. Consociate Health readily offers references and exceeds in the areas of service, evangelism, and leadership.

“We are honored to be recognized by WEX,” said Darren Reynolds, President and CEO of Consociate Health. “WEX has been a key partner of ours since 2005, and has continuously made it possible for us to better serve our clients.”

The Excellence Awards, established in 2008, are presented yearly and recognize WEX Health Partner organizations that have achieved extraordinary notable accomplishments. Award recipients were recognized for reaching significant milestones in 2018 across several areas including growth, evangelism, leadership, innovation, and customer service as well as overall outstanding Partner successes.

The 2018 Partner Excellence Awards were presented in 14 categories: Growth Excellence, Evangelist, Innovator, Market Maker, Sales Excellence, Service Excellence, Solution Visionary, Leadership, New Partner of the Year, COBRA Partner of the Year, Billing Platform Partner of the Year, Technology Solutions Partner of the Year, CDH Platform Partner of the Year, and Partner of the Year.

For more than 40 years, Consociate Health has partnered with employers of all sizes to deliver employee benefit program consulting and administrative services. As a Third-Party Administrator (TPA), Consociate has built a reputation for exceptional accuracy, customer service and a focus on helping employers with innovative cost containment solutions.

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Consociate Health Names Scott Barnes Vice President of Business and Network Development

June 10, 2019

Latest addition to leadership team continues expansion of community-focused healthcare model in the Midwest and Southern US

DECATUR, IL – Third-Party Administrator (TPA) Consociate Health today announced healthcare industry veteran Scott Barnes as the new Vice President of Business and Network Development. Barnes, based in Tennessee, is the latest in a series of top-level executive hires by Consociate as they aggressively expand their community-focused healthcare model throughout the US.

Scott Barnes is a respected sales and marketing leader with almost 30 years of experience in the healthcare industry. Scott will lead the Consociate team in developing and managing the company’s Direct to Employer High Performance Networks.

Barnes comes to Consociate after more than 25 years with HealthSCOPE Benefits St. Louis. Previously serving as a vice president of operations for a St. Louis hospital, Scott became Director of Network Management at HealthSCOPE in 1993 and then led HealthSCOPE Benefits Network Service and Analytics Division until 2009. For the last 10 years, Barnes served as vice president of sales at HealthSCOPE. Scott contributed to a 300% growth of HealthSCOPE Benefits over the last 10 years. During his tenure, Scott developed relationships with strategic medical captive partners and developed a hospital based Community Care Network which utilized direct preferred contracts with key hospital partners and associated physicians, significantly reducing the cost of care in the market.

“Consociate’s growth is focused on developing a team that thrives in our culture of innovation and progress. As we expand nationally, Scott’s expertise in healthcare network development will advance our strategy of building and managing Direct to Employer High Performance Networks and bringing together select high quality/low cost health systems and employers in mutually-beneficial partnerships,” said Consociate President Darren Reynolds.

“We are aggressively growing to meet the needs of clients and we’re excited about the future of Consociate as we engage some of the top leaders in this field to guide our team,” he added.

Barnes is the second recent addition to Consociate leadership. In April, Ziad Rubaie joined Consociate Health as Chief Business Development Officer. His expertise in bringing together strategic healthcare partnerships that drive solutions for clients and their members is highly respected in the industry.

Barnes said, “Employers want clarity in a market where true costs and quality of care are difficult to identify. As Vice President of Business and Network Development, I will lead our team in developing and managing those networks. I joined Consociate Health because I share the vision that an independent TPA in partnership with employers and select high performance providers can reverse run away medical cost and improve member health.”

Existing partnerships with nearly 20 healthcare systems have allowed Consociate to perfect its community centric model using data integration strategies and data driven decision support resources. That success, and the need for more patient-centered service from TPAs industry-wide, led to the decision to expand.

For more than 40 years, Consociate Health has partnered with employers of all sizes to deliver employee benefit program consulting and administrative services. As a Third-Party Administrator (TPA), Consociate has built a reputation for exceptional accuracy, customer service and a focus on helping employers with innovative cost containment solutions.

Through data analytics, Consociate provides its clients with personalized analysis of their plans to ensure they have quality data and are using that data to make educated decisions.

Essential data analytics allow Consociate Health to integrate claims, eligibility, financial and other healthcare data into a consolidated system database; analyze member health and then identify cost drivers; monitor health plan utilization; and forecast employer healthcare costs – which allows them to develop a strategy to manage and control healthcare costs for employers and members.

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