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New information for OIPA-sponsored Workforce Blue Plan

November 05, 2013
TOPICS: OIPA
The OIPA sponsored Workforce Blue program, which is currently available for companies with 2-150 employees, will change on Jan. 1, 2014.

Beginning at this time, no new groups with 2-49 employees can enroll. Current participants with less than 50 employees can choose to extend their plan period through December of 2014. New participants with less than 50 employees can still be added through December 2013.

The program will continue as is for companies with 50-150 employees. All other participation requirements will remain the same. Members should discuss plan options with their insurance agent.


New Delta Dental rates available for OIPA members

Delta Dental has released its OIPA partner rates for October 2013 through September 2014. 100 percent participation is required. Contact Regina Mullennix, OIPA Membership Benefits Consultant for more information at 918.724.8551 or reginam@oipa.com.

                  Breakdown of Delta Dental rates

                                           

Plan Number

Plan Name

Orthodontics

EE

ES

EC

EF

9941

PPO - Choice Advantage

with ortho

$18.72

$37.44

$56.06

$74.78

9942

PPO

with ortho

$24.34

$48.62

$70.74

$95.06

9943

PPO Plus Premier

with ortho

$29.62

$59.24

$86.58

$116.18








9944

PPO - Choice Advantage

no ortho

$18.72

$37.44

$48.32

$67.04

9945

PPO

no ortho

$24.34

$48.62

$60.62

$84.30

9946

PPO Plus Premier

no ortho

$29.62

$59.24

$74.10

$103.70




Information update on the Affordable Care Act for small employers

In Oklahoma, small employers are defined as "companies with 50 or fewer employees." When determining if you are a small or large employer in 2014, part-time employees must be included in this calculation, regardless of number of hours worked.

Although small employers are exempt from the recently postponed employer mandate under the Patient Protection and Affordable Care Act (Obamacare), small employers will be subject to many other PPACA provisions that will have an impact on costs. The provisions below will apply as of the first day of the plan year beginning on or after January 1, 2014, and may significantly affect premiums. 


Deductible/out-of-pocket ceilings

Non-grandfathered, fully insured small employer plans must comply with in-network deductible maximums, which are generally $2,000 for an individual and $4,000 for a family in 2014 (amounts will be indexed annually for years after 2014).

Small group insurance carriers will no longer issue deductibles over these levels for non-grandfathered, small employers even if the employer has a self-insured Health Reimbursement Account (HRA) that brings the deductible down below these new maximums. This new requirement will cause an employer's premiums to increase significantly if it currently has a high deductible health plan with an HRA, because small employer non-grandfathered plans must now have deductibles that do not exceed $2,000 in-network for an individual and $4,000 for a family.

Additionally, all non-grandfathered plans (large and small, fully insured, and self funded) are subject to overall in-network out-of-pocket limits of $6,350 for self-only and $12,700 for other than self-only in 2014 (amounts will be indexed annually).  Depending on your group's current out-of-pocket maximums, this may cause an increase in premiums if you have to lower the out-of-pocket maximum. Under PPACA, out-of-pocket maximums must include deductibles, coinsurance and copayments for essential health benefits.


Adjusted Community Rating

Under a community rating system, health status, gender, industry and group size may not affect the premiums for a small employer health plan. Age, geographic location, family composition and tobacco usage are allowable rating factors.

Starting Jan. 1, 2014, the law limits age rating bands to 3:1 (currently 5:1 or more). This means that the rate for the youngest age band (under 21) and the highest age band (65 and over) may not differ by more than three times. A 1.5:1 rate adjustment is allowed for tobacco use, however this will be difficult to police or administer in the small group market.

Small employers may be impacted by this new adjusted community rating requirement, resulting in significant premium increases or decreases to certain employer groups. For instance, the effect of Adjusted Community Rating on a young, healthy, male workforce will be a significant increase in cost, while employer groups with adverse medical risk, or groups with many employees in higher age bands, will see their premiums reduced.

Although some carriers will provide age-banded rates on their billing statements, employers affected by the Age Discrimination in Employment Act are encouraged not to charge age-based premiums to employees, as charging employees age 40 or older more for a benefit will likely violate the ADEA.


Health Insurance Marketplace (Exchanges)

All employers, even those not offering coverage, were required to provide employees with a written notice of the availability of health coverage through an Exchange, and the circumstances under which the employee may be eligible for a subsidy, by Oct. 1, 2013. Although Oklahoma will not create an Exchange, the Federally Facilitated Exchange completion date is set for the fourth quarter of 2013.

For employees hired on or after Oct. 1, 2013, employers are required to provide the notice to each within 14 days of an employee’s start date. The notice can be provided in writing either by first-class mail, or electronically if the Department of Labor's electronic disclosure safe harbor requirements are met. An Exchange Notice template is available at http://www.dol.gov/ebsa/pdf/FLSAwithplans.pdf.


Small Employer Tax Credit

For 2010-2013, employers with fewer than 25 full-time equivalent employees who pay at least 50 percent of the premium costs and whose employees earn below $50,000 on average annually may be eligible for up to a 35 percent premium tax credit (25 percent if tax exempt). However, beginning in 2014, the credit will only be available to small businesses that purchase coverage through an Exchange. To see if you qualify, refer to IRS Notice 2010-82, IRS Form 8941, and contact your CPA and/or attorney.


Pre-Existing Condition Exclusions

Plan exclusions for those of any age with a pre-existing medical condition will be removed. Previously, the elimination of pre-existing condition limitations only applied to children under age 19. 


Waiting Periods

Service requirements for health insurance eligibility may not exceed 90 days. Since plans may not impose more than a 90-day waiting period, many carriers will be eliminating "First of the Month Following 90 Days of Employment" language from their contract options. Using "three months" instead of 90 days is also not permitted.


Taxes and Fees

In addition to the above changes, which are effective when plans renew in 2014, there are several fees that will continue or begin Jan. 1, 2014: The PCORI/CER fee, the Health Insurer Program fee and the Transitional Reinsurance Program fee.

Many carriers are projecting that the total of the fees will add 3-4 percent to premiums. The increase will apply to employee and dependent tiers.

Finally, medical carriers are offering small groups the option to postpone certain aspects of health care reform by changing their anniversary date. These options should be considered carefully, with guidance from legal counsel specializing in employee benefits.
 
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