Category: Healthcare Industry News

Many employee benefits are subject to annual dollar limits that are periodically increased for inflation. The IRS recently announced cost-of-living adjustments to the annual dollar limits for various welfare and retirement plan limits for 2020.

Although some of the limits will remain the same, many of the limits will increase for 2020.

Employers should update their benefit plan designs for the new limits, and communicate the new benefit plan limits to employees.

HDHPs and HSAs

The health savings account (HSA) contribution limits will increase to $3,550 for individuals and $7,100 for families, effective Jan. 1, 2020. However, the catch-up contribution for HSA-eligible individuals who are age 55 and older will remain at $1,000.

For plan years beginning on or after Jan. 1, 2020, the high deductible health plan (HDHP) minimum deductible will increase to $1,400 for individuals and $2,800 for families. The HDHP maximum out-of-pocket limit will increase to $6,900 for individuals and $13,800 for families.

Health FSAs

The health flexible spending account (FSA) dollar limit on employee salary reduction contributions is $2,750 for taxable years beginning in 2020. There is no change for dependent care FSA contributions.

401(k) Plan Contributions

The employee elective deferrals for 401(k) contributions and catch-up contributions will both increase $500 for 2020. The pre-tax contribution limit will increase to $19,500. The limit on catch- up contributions will increase to $6,500.

Transportation Fringe Benefits

The monthly limits on transit pass and vanpooling (combined), and parking will increase $5 each for 2020, bringing the monthly limits for each to $270.

Adoption Assistance Benefits

The annual tax exclusion for adoption assistance benefits will also increase from $14,080 to $14,300 for 2020.

For More Information

Contact us today to learn more about the updated limits, or for copies of employee communications that detail these changes.

Each year, the Kaiser Family Foundation and the Health Research & Educational Trust conduct a survey to examine employer-sponsored health benefit trends. Some highlights from the 2019 survey include the following:

Plan Enrollment Trends

• Preferred provider organizations (PPOs)—44% of workers covered
• HDHP/SOs—30% of workers covered
• Health maintenance organizations (HMOs)—19% of workers covered
• Point-of-service (POS) plans—7% of workers covered

Health Insurance Premiums

The average premium rose 4% for single coverage and 5% for family coverage—around $7,188 and $20,576 respectively.

Worker Contributions

In dollar amounts, workers contributed $1,242 and $6,015 toward their premiums for single coverage and family coverage respectively.

Self-funding

Similar to the previous year, 17% of small employers have partially or fully self-funded plans, and 80% of large employers have partially or self-funded plans.

Contact Consociate Health for more information on benefit offerings or to learn what you can do to control your health care costs.

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.

Resources

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.

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.

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.

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.

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.

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)

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.