Insight to Action

Want to Improve Population Management? Make Sure Your Health Plan is Aligned with Your Strategy

26 January 2017

Implementing a care management program designed to promote healthy (and cost-effective) member choices can make a real impact on healthcare utilization and costs. But is your self-funded plan optimized to support these efforts? If not, your care management strategy could fall short of its goals. Cammack Health was privileged to work with Montefiore Health System of New York on a comprehensive program focused on moving employee health and cost trends in a positive direction.

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Executive Roundtable: Benefits to Retain Key Leaders and Physicians

4 January 2017

What benefits can you offer your key executives and physicians to keep them from jumping ship? In today’s shifting healthcare landscape, there are measurable impacts on your physicians and health care professionals and the competition for talent is fierce. Join us next Tuesday, January 10th for a roundtable discussion to explore various topics related to executive and physician benefits. Attendees will converse and interact with board members from the region’s top hospitals, CEO’s from the most innovative health care institutions, and Aon’s dedicated team of practitioners.

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Don't Overlook the Value of Good Health Plan Governance

14 December 2016

Our work with self-funded health plan sponsors striving to control costs and improve member health often reveals commonly overlooked factors that can have a big impact. This is especially true for healthcare systems where the organization’s business strategy overlaps with health plan objectives. For example, our experience has shown that establishing a broad-based governing body that includes key stakeholders who are driving towards value based care is critical to achieving alignment and driving results.

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Wearing Two Hats: Maintaining Privacy When the Employer is the Provider

10 November 2016

In an effort to contain costs, a growing number of self-insured healthcare employers are implementing medical management programs to target outreach to high-risk members. Some have decided to manage their program internally, posing a critical question: When the employer and the provider are one in the same, what’s the best way to assure employees their protected health information (PHI) is protected and kept private?HIPAA draws a clear distinction between health plan and employer when it comes to PHI: the plan may have access to PHI, the employer may not.

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Unpacking the Survey: Hospitals are Getting Creative with Contributions

7 September 2016

In the olden days (before the PPACA), employers could charge whatever they wanted for health care coverage with certain common sense limitations. For example, you couldn’t charge more than coverage was worth, and you didn’t want to charge so much that only the sickest people took your plan (avoiding “adverse selection”). With the arrival of the PPACA, there are now rules around what you can charge if you want to claim that your plan is “affordable”.

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Benefits & Healthcare Update: IRS Reminds Employers That Certain Nonmedical Wellness Incentives Are Taxable Income

12 July 2016

The IRS recently released a memorandum reminding employers about the tax treatment of wellness program incentives and employer reimbursement of wellness program-specific premiums. While the memorandum did not break any new ground, it is a useful recap of the IRS rules regarding the taxability of wellness incentives.

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Benefits & Healthcare Update: EEOC Publishes Final Rules for Wellness Programs under ADA, GINA

17 May 2016

On Tuesday, May 17th, the Equal Employment Opportunities Commission (EEOC), the guardian agency of the Americans with Disabilities Act (ADA) and the Genetic Information Nondiscrimination Act (GINA), published its final rules for the operation of wellness programs under the two workplace nondiscrimination statutes. For the most part, the final rules affirm EEOC’s approach as outlined under the proposed rules that the agency published early last year.

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Benefits & Healthcare Update: Departments Release New Guidance on ACA Cost Sharing Limits, HSA Rules

4 May 2016

On Friday April 29, 2016, the Internal Revenue Service (IRS) released HSA contribution rules and HSA-eligible HDHP plan design rules for the 2017 plan year. Previously, the Department of Health and Human Services (HHS) released proposed rules for the out-of-pocket maximum limits applicable to non-grandfathered health plans under the ACA. Remember, there are two sets of rules post-ACA: one regarding out-of-pocket maximum limitations for non-grandfathered group health plans under the ACA, and another set of rules for Health Spending Accounts (HSAs) and HSA-qualifying High Deductible Health Plans (HDHPs) under the Internal Revenue Code. Out-of-pocket Maximum Limitations under ACA For non-grandfathered group health plans, out-of-pocket maximums cannot be greater than $7,150 for single coverage and $14,300 for non-single/family coverage for the 2017 plan year.

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Benefits & Healthcare Update: Church Plan Exemption from ERISA Does Not Apply to Religiously-Affiliated Hospital

31 March 2016

On March 17th, the Seventh Circuit Court of Appeals published the second appellate opinion concluding that plans established by religiously affiliated employers, including hospitals, do not enjoy the church plan exemption from ERISA because the plan was not established by a church. Since the church plan exemption does not apply to these plans, the plans must meet ERISA's requirements regarding plan documentation, filing, legal protections, and appeal procedures. This Seventh Circuit opinion follows much the same reasoning as the first decision on this subject that was handed down by the Third Circuit in December 2015: by the terms of the statute, the exemption from ERISA only applies to plans established by churches themselves, not to plans established by church-affiliated organizations.

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Benefits & Healthcare Update: Agencies Propose a Revised Summary of Benefits Coverage Template

2 March 2016

On February 25, 2016, the Department of Health and Human Services, the Department of Labor, and the Internal Revenue Service proposed significant revisions to the Summary of Benefits Coverage ("SBC") template. The proposed changes will require additional questions to be included in the SBC as well as new disclosures from health plans.

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​When Pain (and the MRI) Lies

9 February 2016

We hear a lot about "unnecessary care" driving health costs, but how do we judge what is unnecessary? Although it's common to focus on people reporting symptoms, another way to do it is to study what healthy people look like, so we can establish what "normal" is. A recent study published in the American Journal of Neuroradiology showed that "normal" (asymptomatic) adults with no reported back pain nevertheless have a high prevalence of related abnormalities visible in their MRIs. The same herniated disc "requiring" surgery in one patient could be a painless, normal feature of aging in another patient.

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Benefits & Healthcare Update: IRS Increases Affordability Safe Harbors, Clarifies Treatment of Waiver Incentives

13 January 2016

At the end of 2015, the Internal Revenue Service (IRS) provided guidance in Notice 2015-87 with respect to Health Reimbursement Accounts (HRAs) and how to calculate the affordability of coverage. While much of the guidance restates and formalizes previous remarks from the agency, there are a couple new developments in the Notice regarding affordability that can affect the way employers set their employee contributions and structure their plans. Affordability Safe Harbors Indexed In the Final Rule regarding the employer mandate, the IRS established three safe harbors for providing affordable medical insurance to ACA full-time employees: the Federal Poverty Level safe harbor, the Form W-2 safe harbor, and the Rate of Pay safe harbor.

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Benefits & Healthcare Update: IRS Pushes Back Due Date for Form 1095-C to March 31, 2016

29 December 2015

On Monday, December 28th, the Internal Revenue Service (IRS) published Notice 2016-4 announcing transitional relief for health insurance information reporting: Forms 1095-C are now due to individuals by March 31st, 2016 and to the IRS, along with the Form 1094-C, by June 30th, 2016 when filing electronically. This welcome reprieve allows employers and other filing entities more time to establish systems for generating and completing the Forms. Notice 2016-4 can be found on line here: https://www.irs.gov/pub/irs-drop/n-16-4.pdf If you have any questions about health insurance information reporting, please contact Ed Doherty at 646-839-8251 or via email at EDoherty@cammackhealth.com.

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Benefits & Healthcare Update: Congress Will Delay Cadillac Tax for Two Years

17 December 2015

Congress is expected to pass a year-end budget deal for 2016 that delays levying the tax on high cost health insurance, known as the Cadillac Tax, until 2020. The deal also includes tax delays on medical devices and health insurers, as well as other provisions affecting health insurance and employee benefits generally. Cammack Health will release another Alert once the budget deal becomes law and more details are known. If you have any questions about the Cadillac Tax, please contact Ed Doherty at 646-839-8251 or via email at EDoherty@cammackhealth.com.

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Benefits & Healthcare Update: Agencies Finalize ACA Market Reform Rules, Make No Substantial Changes

4 December 2015

On November 18, 2015, the DOL, HHS, and IRS jointly published final rules on grandfathered plan status, pre-existing condition exclusions, lifetime and annual limits, rescissions, dependent coverage, appeals, and patient protections. The final rules formalize and merge the previously issued interim rules and sub-regulatory guidance.

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Benefits & Healthcare Update: EEOC Issues Rules for Wellness Plans Offering Incentives for Dependent Participation

10 November 2015

On Friday, October 30th, the Equal Employment Opportunity Commission (EEOC) published proposed rules for how wellness programs can provide incentives for spouses to participate without violating the Genetic Information Nondiscrimination Act (GINA). The proposed rules make clear that a wellness plan may offer incentives for a spouse to complete a medical examination, a Health Risk Assessment (HRA), or similar medical questionnaire. Under the proposed rules, a wellness plan may offer an incentive to an employee whose spouse (1) is covered under the employee's health plan; (2) receives health or genetic services offered by the employer, including as part of a wellness program; and (3) provides information about his or her current or past health status as part of a HRA.

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Benefits & Healthcare Update: New York City Ordinance Requires Employers to Offer Pre-Tax Transit Benefits

9 November 2015

Effective January 1, 2016, New York City Local Law 53 will require all employers with more than 20 full-time employees to offer all full-time workers the opportunity to use pre-tax earnings to purchase qualified transportation fringe benefits under Section 132(f) of the Internal Revenue Code. Although the law is effective January 1, 2016, employers will not be subject to any penalties for violating the law until July 1, 2016. After that date, any employer that has violated the law will have 90 days to cure their first violation.

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Benefits & Healthcare Update: Affordable Care Act's Automatic Enrollment Requirement Repealed

9 November 2015

The "automatic enrollment" provision of the Affordable Care Act, never enforced, has been repealed under the Bipartisan Budget Act of 2015, signed by President Obama on November 2, 2015. As written in the 2010 ACA legislation, the automatic enrollment provision required employers that are subject to the Federal Labor Standards Act (FLSA) and which employed more than 200 full-time employees to automatically enroll new full-time employees in one of the employer's health plans, subject to any waiting period authorized by law. Notices would have been required giving employees an opportunity to opt out of any coverage in which the employee was automatically enrolled.

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Benefits & Healthcare Update: IRS Publishes Updated Health FSA Contribution Limit, Qualified Transportation Amounts

9 November 2015

On Thursday, October 21st, the Internal Revenue Service (IRS) published in Revenue Procedure 2015-53 increases to amounts that adjust annually for inflation, including the contribution limit for health Flexible Spending Accounts (FSA) and the pretax limits for certain Qualified Transportation Fringe Benefits. For 2016, the limitation on employee contributions to health FSAs remains $2,550, the same as 2015. The 2015 monthly pretax limitation for transportation in a commuter highway vehicle and mass transit also remains the same as 2015, $130.

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Presentation: HFMA New Jersey/Metropolitan Philadelphia Annual Institute

12 October 2015

There were some great questions from our audience at the HFMA NJ PA National Institute event last week. Beth Barker, Director of Compensation & Benefits at Southcoast Health, and I presented on the Southcoast Employee Benefit experience in a session called “Using Your Employee Benefit Plan to Advance Your Value-Based Care Strategy and Reduce Hospital Expenses”.

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Sharing Experiences of Women in Leadership

1 October 2015

Cammack Health is excited to host students from the Nichols College course “How Women Lead” to share our experiences as professional women. The class studies the challenges and opportunities for young women entering the workplace and will meet with businesswomen from various organizations to discuss their personal journeys.

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Benefits & Healthcare Update: IRS Publishes Final 2015 Instructions for Health Insurance Information Reporting

1 October 2015

On September 18, 2015, the Internal Revenue Service (IRS) published the final 2015 instructions for completing Forms 1094-C and 1095-C. The 2015 instructions clarify the reporting of multiemployer plan coverage, make a substantive change in the manner in which offers of COBRA coverage are reported, and clarify how employers report HRA coverage paired with insured medical benefits.

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Surveying the Future: Releasing Our Tenth Annual Benefits Survey of Hospitals

18 August 2015

This week, participants in Cammack Health's Benefits Survey of Hospitals are receiving their copies of the final report. With over 160 hospitals represented across 89 health systems in seven states, the survey has grown considerably from its humble beginnings ten years ago. This year, the impending Cadillac tax is the troubling specter on the horizon of healthcare reform.

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Benefits & Healthcare Update: Departments Release New Guidance on ACA Cost Sharing Limits, HSA Rules

6 May 2015

The Department of Health and Human Services (HHS) and the Internal Revenue Service (IRS) recently released plan design rules for the 2016 plan year. The biggest change is the clarification of how out-of-pocket maximum limitations work under the Affordable Care Act (ACA): non-single coverage limits "embed" the single coverage limit in the sense that an individual cannot owe pay more than the single limit regardless of whether the individual has single coverage or is a member in non-single coverage. Remember, there are two sets of cost sharing rules post-ACA: one regarding out-of-pocket maximum limitations for all large group health plans under the ACA, and another set of rules for Health Spending Accounts (HSAs) and HSA-qualifying High Deductible Health Plans (HDHPs) under the Internal Revenue Code.

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Benefits & Healthcare Update: EEOC Proposes Wellness Regulations, Adding Regulatory Limits to Program Design

22 April 2015

On April 20, 2015, the Equal Employment Opportunity Commission (EEOC) published proposed regulations for keeping employer-maintained wellness programs compliant with the Americans with Disabilities Act (ADA). This is welcome guidance after litigation brought by the EEOC sparked discourse over wellness programs last year.

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Reporting Coverage on Your Taxes

17 March 2015

While employers have been focusing on the employer mandate—naturally—there's the other side of the coin that came into effect in 2014 without delay: the individual mandate. The individual mandate requires everyone to either have health insurance coverage every month of the year or face a penalty unless you qualify for a hardship exemption.The IRS recently released some guidance for everyone here: http://www.irs.gov/Affordable-Care-Act/Individuals-and-Families For most Americans, they will have coverage through their employers for the entire year, and they simply will check a box on their Form 1040.

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Obligation to Offer Benefits to New Hires

11 February 2015

Perhaps one of the biggest pains in the neck about the employer mandate is that employers will have to track some new employees for a year to determine whether they're actually working full-time hours or not. The process is this: First, at hire, is the position expected to work 30 hours or more per week? If yes, then that employee is a full-time employee from the start, regardless of how long you expect to keep that employee around.

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Keeping Tabs on Who is a Full-Time Employee

11 February 2015

The ACA requires that larger employers offer medical insurance to full-time employees and report on their offer of coverage after the end of the year. To make sure that you're correctly administering the offer of medical insurance—or at least to know the amount of potential liability you'll face for failing to offer insurance—employers should have a separate method of track who is a full-time employee for the purposes of the ACA. This could be something as simple as a separate Excel spreadsheet with a list of the full-time employees by month, or you could program this function into your HRIS system.

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Introduction

11 February 2015

Hello everyone: welcome to Insight into Action, the Cammack Health blog! With this blog we're hoping to provide you with a more regular dose of the latest and greatest in the rapidly changing world of employee benefits, along with some insights that come up in our day-to-day operations. Because I lost a bet, I'll be authoring most of the content of the blog for now, and so we'll be focusing on many of the compliance challenges that have arisen since the implementation of the Affordable Care Act, aka Obamacare.

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