Published on March 6, 2014
Affordable Care Act (ACA) 2014 Compliance Plan Webinar Series Session #2 ACA’s Biggest Challenge: Employee Eligibility Verification Presenter: Si Nahra, Ph.D., President February 20, 2014
About Health Decisions, Inc. Pioneering Specialists in Group Health Care Post-Payment Administration For Over 25 Years Customer Philosophy: Respect for Existing Procedures Emphasis on Customization Focus on Solutions Copyright Health Decisions, Inc. 2/2014 2
2014 ACA Series FOCUS Non-grandfathered, calendar year plans. “Blue Collar” Compliance. Delays and technical intricacies no excuse. Comply not just because you have to. Comply in a way that helps your plan. Copyright Health Decisions, Inc. 2/2014 3
2014 ACA Series Month Current Focus January February 2014 ACA Plan Webinar Series 1/30: ACA is here. Are you ready? What you should have done and in place now. Prior Year Close-out 2/20: ACA’s Biggest Challenge: Employee Eligibility Verification. Opportunity for savings and employee engagement. March 3/20: ACA Taxes and Dependent Verification How much. How to minimize. How to manage. April 4/17: ACA Cost Sharing (Preventive Care and OOP Maximum) Ticking time-bomb of liability. Copyright Health Decisions, Inc. 2/2014 4
Quick Review What you should have done. • Reporting to employees – – – • Benefits – – – – – – • ACA Compliance Self-Assessment Tool Selected Essential Health Benefits No cost sharing for federal preventive care benefits No pre-existing conditions No lifetime maximums Dependents covered until 26 Clinical trial coverage Safe Harbors – – • W-2 plan values Summary of Benefits and Coverage (SBC) Exchange Notices available now. Call 734-451-2230 Ask for Leslie. E-mail email@example.com Minimum Value Safe Harbor Affordability Safe Harbor New Out-of-Pocket rules implemented Copyright Health Decisions, Inc. 2/2014 5
Quick Review What You Should Have in Place. Start NOW • • Complet e First Quarter • • • Compile Needed Data Files o Payroll Data (with history) o Enrollment Rosters (with history) o Paid Claims (transactions not summaries) Assess Data files for accuracy and use Reconcile payroll facts with enrollment facts o Expect major inconsistencies o Expect ineligibles o Expect late terminations Survey all employees o Verify dependent eligibility for two ACA taxes in 2014 o Collect SSN for ALL employees, retirees, and family members o Two-way communication (authorizations & “good faith” efforts) Confirm cost sharing controls o Preventive Services Zero cost sharing o Out-of-pocket maximum limits Copyright Health Decisions, Inc. 2/2014 6
ACA “Have To” “W-2” For Health Coverage ACA requires employers to include in annual IRS filings: •The health coverage status of all employees: • those with and without health coverage; • those eligible and not eligible. • By coverage type (single, two-person, family •With month-by-month accounting. •Sent via electronic rosters meeting IRS technical specifications. •AND reports to each employee confirming what was sent about them. 2016 reports account for 2015 2014 testing best preparation for 2015 accounting Copyright Health Decisions, Inc. 2/2014 7
ACA “Have To” The IRS will •Compare these rosters to rosters from the new State Health Exchanges. •Use these rosters to enforce • Individual subsidies and • Employer “shared responsibility” Employers not complying face possible penalties and fines. •ACA •IRS Copyright Health Decisions, Inc. 2/2014 8
Reality of Employee Eligibility Verification There is no one place employers can go to get all the required information. Employers have to piece together a reporting puzzle. •Payroll system vendors have pieces of the puzzle. •Group health plan administrators have pieces of the puzzle. •Enrollment maintenance and COBRA vendors have pieces of the puzzle. •Some puzzle pieces may be missing. Puzzle pieces will not fit together easily. Enrollment No common ID Input errors Different codes Missing data No history Incompatible systems Incompatible layouts Payroll … We’ve seen it all and it “ain’t” pretty. Copyright Health Decisions, Inc. 2/2014 9
ACA “Help Your Plan” What the Payroll/Enrollment Match Reveals Savings Excess Administrative Fees Excess Insurance Premiums Excess Stop-loss Premiums Duplicate Payments and Fees Claims Paid After Termination Claims Paid During Coverage Lapses Claims Paid for Ineligibles Phantoms (Type 1): Employees enrolled beyond termination date. Phantoms (Type 2): Unknown persons enrolled in one or more plans. Errors: Employees enrolled who are ineligible. Duplicates: Employees enrolled in multiple plans. Wrong Tier (Type 1): Single enrollees in non-single coverage categories. Wrong Tier (Type 2): Two-person coverage enrolled as family. COBRA: COBRA enrollees not COBRA eligible. Not “whether” but “how much”. Copyright Health Decisions, Inc. 2/2014 10
ACA Plan This Month’s “To Do” List Payroll and Enrollment: Combination/Reconciliation •Start now to be ready to confirm what you can do. •Start now to have time to fix what needs fixing. •Start now to be ready 1/2015 and avoid penalties. •Start now to get savings now. Copyright Health Decisions, Inc. 2/2014 11
For More Information Contact firstname.lastname@example.org 734-451-2230 Connect with me on LinkedIn Add me to your circles on Google+ Like us on FaceBook Follow us on Twitter Copyright Health Decisions, Inc. 2/2014 12
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