CMS Cuts Some Slack on HRA Reporting Rules

September 28th, 2011 | No Comments |
Category: CDHC, Compliance and Regulatory, HRA, Health Reimbursement, Uncategorized

The Centers for Medicare and Medicaid Services (CMS) provided badly needed relief to Health Reimbursement Arrangement (HRA) administrators in an Alert that was issued on Thursday.

HRAs have been subject to a quarterly reporting requirement under Medicare Secondary Payer (MSP) rules that have been in effect for years. What this means is that HRA administrators must provide participant data to CMS so it can determine when Medicare is primary or secondary coverage to an employer-provided HRA.

One key exception was for participants with an annual benefit level of less than $1,000. Effective October 3, 2011, the Alert increases that threshold to $5,000. The practical impact will be a significant reduction in the number of participants who must be reported.

Another important change relates to participants who have exhausted their account balances for the year, where the employer has already fully funded the account. These participants should now be reported to CMS as terminated.

For the past two weeks, there were several indicators that CMS might relax this reporting requirement. A September 7, 2011, teleconference indicated to us that CMS might make this change, and we anticipate that other positive changes may be in the works.

Stay tuned.

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New Regulation Requires Health Plan Option Summary in 2012

September 1st, 2011 | No Comments |
Category: CDHC, Compliance and Regulatory, Health Care Reform, PPACA, Uncategorized
This month, the Departments of Labor and HHS proposed rules for the “uniform summary of coverage” that is required under PPACA. Heath insurers and group health plans (including grandfathered plans) must provide consumers with clear, consistent and comparable information about their health plan benefits and coverage beginning in 2012. Specifically, the proposed regulations provide rules implementing PPACA provisions that would ensure consumers have access to two forms that will help them understand and evaluate their health insurance choices.These forms include:

  • A Summary of Benefits and Coverage
  • A uniform glossary of terms commonly used in health insurance coverage

Summary of Benefits and Coverage

The summary document will include the key features of the plan or coverage such as the covered benefits, cost-sharing provisions, and coverage limitations and exceptions. Consumers will receive the summary when shopping for coverage, enrolling in coverage at each new plan year, and within seven days of requesting a copy from a health insurance issuer or group health plan.

The Summary of Benefits and Coverage will also include a new, standardized health plan comparison tool called “Coverage Examples” that illustrate what proportion of care expenses a health insurance policy or plan would cover under common benefits scenarios. The Center for Consumer Information and Insurance Oversight (CCIIO) will provide standards for plans and issuers to simulate claims processing for each scenario so consumers can see an illustration of the coverage they get for their premium dollars under a plan.

Uniform Glossary of Terms

Under the proposed regulations, insurance terms will be the same across all plans. Insurance companies and group health plans will be required to make available a uniform glossary of terms used in health insurance coverage, for example “deductible” and “co-pay.” This will allow an easier comparison of insurance plans, and the Departments of HHS and Labor will post the glossary on both www.HealthCare.gov and www.dol.gov/ebsa/healthreform/.

Click here to read the proposed regulations.

Click here to read the Model Summary of Coverage.

Click here to read the fact sheet.
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