ARRA COBRA Subsidy Update
The ARRA COBRA subsidy has expired and has not been extended. Current COBRA notices should be in the pre-ARRA format. If BMC Benefit Services sends your COBRA notices, we’ve already updated our files to the pre-ARRA notices.
Carrier Product Update
Two of the area’s major carriers, Keystone/Independence Blue Cross and Aetna, have updated their product portfolios as of October 2010. Depending on your plan anniversary and group size, you may be able to renew “as is” if you desire or you may have to amend to a current plan offering. With Keystone, there will be fewer “mix and match” options in a move to packaged “as is” plans, including prescription and vision benefits. All of the new plans meet the new health care reform guidelines, specifically waiving co-pays for preventive services, eliminating annual or lifetime dollar maximums on coverage for essential benefits and covering adult children to age 26.
If your coverage is currently with Keystone/Independence Blue Cross or Aetna, you can expect to see a letter from them regarding the new plans; however, BMC has already had presentations from both carriers and is prepared to present all available options at your plan anniversary.
Health Care Reform Update
The prohibition of lifetime limits on essential health benefits, prohibition of certain annual limits, extended eligibility of dependent children and prohibition of pre-existing condition exclusions are all generally effective as of the first day of the first plan year beginning on or after October 1, 2010. There are some “special relief” situations where compliance is postponed, however, for most clients who have fully insured plans with the major carriers, the carriers are amending the plans (as above) to comply, thereby assuring your compliance.
Health Care Reform Update on FSAs and HRAs
As of plan years beginning January 1, 2011, medical FSAs may no longer reimburse drugs which are not prescribed. The drug does not have to be a prescription drug to be covered, but must be prescribed. As a result, an over the counter drug prescribed by a physician can still qualify as of 2011. Effective 2013, annual medical FSAs will be capped at $2,500 per participant. The cap is to be adjusted for inflation after 2013.
We have an excellent overview, Health Care Reform: What Employers Need to Know, that was prepared by the national law firm of Miller Johnson and provided to us by Brown and Brown, one of BMC Benefit Services’ business partners. Some of the information above is based on their advisory.