Patient Protection and Affordable Care Act (PPACA) retroactive termination policies are in effect

We are writing with an important notice about the retroactive termination policy that applies to all fully-insured customers. AmeriHealth New Jersey wants to ensure that you, your staff, and your customers understand the importance of compliance with this policy as part of health care reform. If you have not discussed this with your staff and customers already, now is the time to take action to help avoid potential financial penalties to your customers.

The retroactive termination policies

Per the PPACA retroactive termination guidelines, the period of time in which AmeriHealth New Jersey will retroactively terminate members for fully-insured groups has changed from 60 days plus the current month to 30 days plus the current month in which the request was made. The PPACA prohibits health insurers and group administrators from rescinding coverage except in the case of fraud, intentional misrepresentation of material facts, or failure to pay required premiums. A rescission is defined as a cancellation of coverage that has a retroactive (occurring in the past) termination date.

Please note that when requests for retroactive terminations are submitted, AmeriHealth New Jersey will regard the submission as certification that the termination is in the normal course of business and certification that no premium/contribution was paid by the member/dependent for that period. If a member paid premium or contributed to the cost of the plan, coverage may not be terminated with a past effective date except in the case of fraud or a misrepresentation of a material fact. The group health plan or health insurance issuer must provide a 30 day written notice of coverage termination to each individual affected by the termination before coverage may be rescinded. The member has the right to appeal the rescission of coverage.

To comply with the PPACA, the AmeriHealth New Jersey retroactive termination policy for fully-insured customers is as follows:

• For fully-insured groups, retroactive terminations may be made for up to 30 days plus the current month (30-60 days). This means that a termination cannot be made for more than 60 days before the date that AmeriHealth New Jersey is notified.

The policy for self-funded groups remains unchanged:

• For self-funded groups, retroactive terminations may be made for up to 60 days plus the current month (60-90 days). This means that a termination cannot be made for more than 90 days before the date that AmeriHealth New Jersey is notified. Self-funded groups can decide how to implement retroactive terminations within this timeframe.

Help your customers avoid potential penalties for non-compliance

If you have not discussed the impact of the PPACA retroactive termination guidelines with your staff and customers we urge you to do so now. By doing this you will help to ensure that retroactive termination requests are processed in accordance with PPACA specifications.

To help your groups to avoid potential penalties, when a termination date is requested that is outside the guidelines above, a letter will be sent to the group administrator that will advise that the termination date has been adjusted to fall within the policy guidelines.

Please be assured that AmeriHealth New Jersey complies with the applicable provisions of the PPACA. Our goal is the same as yours; to provide our customers with quality benefits at the best possible price. We greatly appreciate your efforts to support these initiatives. If you have any questions, please contact your AmeriHealth New Jersey broker representative.

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Horizon BCBSNJ Brief Notes V. 22, No. 906: Affordable Care Act imposes Insurer Fee on premiums
February 20, 2013

Applies to: All insured markets, Federal Employee Program, Medicare, Medicaid, dental and vision

Affordable Care Act imposes Insurer Fee on premiums
Insurer Fee will increase premiums

Many important changes in federal law will affect and are affecting your clients.

The Affordable Care Act, also known as federal health care reform, imposes a fee on health insurance premiums that will increase the cost of buying health care coverage, beginning in 2014. The Insurer Fee is commonly called a premium tax.

The amount of the Insurer Fee on the industry nationwide will be $8 billion in 2014, increasing to $14.3 billion in 2018, and increase based on premium trend thereafter.

Effective date
The requirement is scheduled to begin in 2014, with the first estimated Insurer Fee paid to the Internal Revenue Service by September 2014, based on 2013 data.

Purpose of the Insurer Fee
The Insurer Fee will fund subsidies for individuals and families with household incomes between 100 percent and 400 percent of the federal poverty level. These individuals and families will buy their health insurance through health insurance exchanges, which launch in 2014, and have Open Enrollment in October 2013.

Market segments subject to the Insurer Fee
Please note: The law is not clear on market segments subject to the fee, so this list can change.

How the Insurer Fee works
The Insurer Fee is a permanent premium tax on most insurance companies starting in 2014. The requirement imposes an annual tax on the health insurance industry nationwide, according to the following schedule:

• $8 billion in 2014.
• $11.3 billion in 2015.
• $11.3 billion in 2016.
• $13.9 billion in 2017.
• $14.3 billion in 2018.
• For years after 2018, the fee will be the amount from the previous year increased by the rate of premium growth.

Fees will be prorated for each insurer based on its share of the nationwide premiums that are
subject to the fee for the preceding calendar year.

Impact to your clients
Horizon Blue Cross Blue Shield of New Jersey pays claims and other expenses, including taxes such as the Insurer Fee, from the premiums collected from your clients. To pay increased costs, Horizon BCBSNJ must increase premiums accordingly. The ACA does not permit Horizon BCBSNJ to deduct the Insurer Fee from its federal and state taxes. As a result, if Horizon BCBSNJ’s tax rate is 20 percent requiring a payment of $80 in taxes, Horizon BCBSNJ must collect $100 from its clients to pay the $80.

The total amount that Horizon BCBSNJ will collect from its clients is an estimated $162 million for 2014.

• For insured 51+ groups:
• We have begun to charge the Insurer Fee in renewals.
• For insured two to 50 groups and Individual:
• Currently, we cannot build in the Insurer Fee due to New Jersey’s minimum loss ratio requirements. Horizon BCBSNJ is working with the New Jersey
• Department of Banking and Insurance to address this issue, so future pricing can cover these fees.

Impact to premium bills
Horizon BCBSNJ will not bill your clients all at once. Instead, Horizon BCBSNJ will spread the billing over a 12-month period, starting with March 2013 renewals.

If you have questions, please contact your Horizon BCBSNJ sales executive or account manager.
The information included in this document may be subject to change at any time as laws and regulations and related guidance are issued by state and federal agencies. This document is for educational purposes only.

Please see attached for 2nd Quarter Dental & Vision rate cards pertaining to NJ groups.

• Voluntary & Contributory plans are listed on these rate cards. Products can be sold standalone.
• UHC quotes on eligible, not enrolled.

Remember:

• Voluntary Dental: Only 2 needed to enroll
• Voluntary Vision: Only 1 needed to enroll (Significant price reduction in Vision plans for 2nd quarter)
• Voluntary OBM: Only 2 needed to enroll. (Quote at www.oxfordbenefitmanagement.com)

Top Vol Dental Plans: PIN53, P3366
Top Vol Vision Plans: V1043, V1008

Also see:
UHCDental (Size: 341 Kb )

IRS and HHS Issue Proposed Regulations on Individual Mandate

On January 30, 2013, the Internal Revenue Service (IRS) and the Department of Health and Human Services (HHS) issued two sets of proposed regulations related to the individual mandate provision of the Patient Protection and Affordable Care Act (PPACA).

The individual mandate requires most individuals to have minimum essential coverage or pay a penalty beginning in 2014. The penalty is now called a shared responsibility payment. Some individuals may qualify for an exemption so they will not be required to have coverage or pay a penalty.

The proposed regulations confirm the individual mandate requirements and outline the process for requesting an exemption. The proposed regulations cover:

• What qualifies as minimum essential coverage
• How penalties will be determined and paid
• Who is exempt from paying the penalty
• When individuals can apply for an exemption

1. What Qualifies as Minimum Essential Coverage An individual is considered to have minimum essential coverage for any month in which he or she is enrolled in one of the following types of coverage for at least one day:

• An employer group health plan
• An individual health insurance policy
• A government plan such as Medicare, Medicaid, Children’s Health Insurance Program (CHIP), TRICARE or veterans coverage
• Student health coverage
• Medicare Advantage plan
• State high risk pool coverage
• Coverage for non-U.S. citizens provided by another country
• Refugee medical assistance provided by the Administration for Children and Families
• Coverage for AmeriCorp volunteers

All these types of plans qualify as minimum essential coverage, and there are no additional coverage requirements that must be met.
2. How Penalties will be Determined and Paid
The first penalties will be due when individuals file their 2014 tax returns in 2015. A penalty is determined by calculating the greater amount of either a flat dollar amount or set percentage of income. The annual penalties for 2014 through 2016 are noted below. Beginning in 2017, penalties will increase based on the cost of living.

• 2014: Greater of $95 per adult and $47.50 per child under age 18 (maximum of $285 per family) or 1% of income over the tax-filing threshold
• 2015: Greater of $325 per adult and $162.50 per child under age 18 (maximum of $975 per family) or 2% over the tax-filing threshold
• 2016: Greater of $695 per adult and $347.50 per child under age 18 (maximum of $2,085 per family) or 2.5% over the tax-filing threshold
• If the penalty applies for less than a full calendar year, the penalty will be 1/12 of the annual amount per month without coverage.

3. Who is Exempt from Paying the Penalty for Not Having Coverage
Individuals who meet the following criteria will not pay a penalty if they do not have minimum essential coverage:

• Individuals who cannot afford coverage. Coverage is considered unaffordable if an individual’s contribution toward minimum essential coverage is more than 8% of the annual household income. The monthly contributions are calculated at 1/12 the annual household income to determine if they exceed the 8%.
• Taxpayers with income below the tax filing threshold, which is the amount required to file a federal tax return
• Individuals who qualify for a hardship exemption. This exemption is available to individuals who are not eligible for Medicaid because their state chose not to expand Medicaid, or to individuals who have a personal or financial hardship that keeps them from being able to afford coverage.
• Individuals who have a gap in minimum essential coverage of less than three consecutive months in a calendar year
• Members of religious groups that object to coverage on religious principles
• Members of health care sharing ministries. These are non-profit religious organizations where members share medical costs.
• Individuals in prison
• Individuals who are not U.S. citizens
• Members of Native American tribes

U.S. citizens residing in a foreign country are typically exempt from having minimum essential coverage if they meet certain requirements, such as residing abroad for an entire calendar year. And, residents of U.S. territories (Guam, American Samoa, Northern Mariana Islands, Puerto Rico, and Virgin Islands) are automatically deemed to have minimum essential coverage.
4. When Individuals Can Apply for an Exemption
There are times when a person may request exemption. The Exchange will review the application, issue a certificate of exemption and notify the IRS. Other types of exemptions are claimed when individuals file their federal income tax returns.

• Religious and hardship exemptions are only available when applying through an Exchange.
• Individuals who cannot afford coverage, who experience short coverage gaps, who are not U.S. citizens and who have household incomes below the filing threshold may apply for an exemption through the IRS.
• Members of a health care sharing ministry, individuals in prison and members of Native American tribes may apply for an exemption through either an Exchange or through the IRS when filing a federal tax return.

Comments regarding the HHS regulations are due by March 18, 2013. Comments regarding the IRS regulations are due by May 2, 2013 and a public hearing is scheduled for May 29, 2013

http://s1399.t.en25.com/e/es?s=1399&e=74071&elq=5e5bd5a1e4924b36b6e273f6ffeb6da1

Horizon BCBSNJ Brief Notes V. 22, No. 904: How small employer health care exchanges impact you and the insurance industry
Applies to: Small employer market (two to 50 employees)

How small employer health care exchanges impact you and the insurance industry

Two issues to consider and a call to action

The Affordable Care Act (ACA) requires that Small Business Health Options Programs (SHOPs), commonly called exchanges, be established in all states starting in 2014. Also, the ACA requires insurers that offer small group coverage in the state market outside the exchange to participate in that state’s federal SHOPs exchange in 2014 and beyond.

Horizon Blue Cross Blue Shield of New Jersey supports expanding access to health care coverage, but believes that SHOPs should be phased in after 2014.

Please consider these two issues:

1. Getting SHOPs up and running is highly complex. Under SHOPs, health plans will need to make major operational changes in basic billing and enrollment. This will divert resources from what should be a top priority ensuring individual exchanges work effectively, especially with Open Enrollment less than nine months away.

2. Many key operational details to support enrollment, plan management and financial services are still missing. Horizon BCBSNJ believes it will take more than a year after the release of specifications for health plans and states to make all the major changes needed for SHOPs to work.

A call to action:

We ask that you contact the Obama Administration and your Congress person and urge them to phase in SHOPs after 2014. Contacts in the Obama Administration are:

• Marilyn Tavenner, CMS Acting Administrator.
• Jeanne Lambrew, White House Deputy Assistant to the President for Health Policy.

You may find your representative in the House of Representatives here.

If you have questions, please contact your Horizon BCBSNJ sales executive or account manager

Also see:
BB2013SHOPS (Size: 979 Kb )

Horizon BCBSNJ Brief Notes V. 22, No. 902, Important Changes to Small Group Coverage Options
January 30, 2013 Vol. 22 No. 902

Applies to: Small employer market (two to 50 employees)

Important Changes to Small Group Coverage Options
Horizon Blue Cross Blue Shield of New Jersey is committed to providing quality, affordable health care coverage to support your new sales and retention efforts. That’s why Horizon BCBSNJ is streamlining our current health and prescription drug product portfolio to include select small employer products.

See attached PDF

Also see:
HorizonSmall Group Changes (Size: 172 Kb )