high deductible health plan Archives

Applicability of the Embedded MOOP to Large Group and Self-Funded High Deductible Health Plans

Informal guidance from the Department of Labor (“DOL”) and the Department of Health and Human Services (“HHS”) (the Departments) has called into question a common practice of high deductible health plans regarding how out of pocket maximums are applied.

Generally, where a high deductible health plan offers self and family coverage, the out of pocket maximum for self-only coverage is not applied for individuals who are enrolled in family coverage. For example, if the self-only coverage out of pocket maximum is $6,000, and the family maximum is $12,000, the plan would not pay at 100% until the family maximum is met, even if that means all of the costs are attributable to one individual. This plan design is expressly permitted by the Internal Revenue Service in its guidance for health savings accounts (HSAs) and high deductible health plans.

DOL and HHS are now saying informally that typical plan design is no longer permitted by the Affordable Care Act (“ACA”) –i.e., the maximum self-only limit for HSAs and high deductible health plans must be applied to individuals enrolled in family plans. This is known as the so called “embedded” maximum out of pocket (“MOOP”) rule. The Departments are also indicating that the change is effective for plan years beginning on or after January 1, 2016.

There is some possibility that the agencies will issue more clarifying guidance, but in the absence of such guidance plan sponsors should carefully evaluate the risks of retaining their
current plan design.

This Benefits Brief provides background regarding the cost-sharing provisions under the ACA and summarizes the recent guidance on cost-sharing issued by the Departments. Finally, it
clarifies the applicability of the embedded MOOP to large group and self-funded group health plans.

Read the full report here.

Contact Steven G. Cosby, MHSA, Group Health Insurance Broker and Agent with Cosby Insurance Group, with questions or to request more information and to schedule a healthcare plan evaluation, savings analysis or group plan solution for your company.

2016 HSA Contribution Limits and Minimum Deductibles

IRS Announcement: 2016 HSA Contribution Limits and Minimum Deductibles Adjusted for Inflation

The IRS has released the 2016 inflation adjusted amounts for health savings accounts (HSAs). To be eligible to contribute to an HSA, an individual must be covered under a high deductible health plan (HDHP) and meet certain other eligibility requirements.

Annual Contribution Limitation
For calendar year 2016, the annual limitation on HSA deductions for an individual with self-only coverage under an HDHP is $3,350. The annual limitation on HSA deductions for an individual with family coverage under an HDHP is $6,750.

High Deductible Health Plan
For calendar year 2016, a “high deductible health plan” is defined as a health plan with an annual deductible that is not less than $1,300 for self-only coverage or $2,600 for family coverage, and the annual out-of-pocket expenses (deductibles, co-payments, and other amounts, but not premiums) do not exceed $6,550 for self-only coverage or $13,100 for family coverage.

Read the full IRS Announcement here. (See Revenue Procedure 2015-30.)

Please contact Steven G. Cosby, MHSA, Group Health Insurance Broker and Agent with Cosby Insurance Group, with questions or to request more information and to schedule a healthcare plan evaluation, savings analysis or group plan solution for your company.

The Biggest Healthcare Benefits Decision You’ll Have to Make This Year

This year, your company may push you to a high-deductible health plan that looks cheaper, but it may not be.

This benefits open-enrollment period, your employer may ask you—even force you—to enroll in a high-deductible health insurance plan with a health savings account. Nearly three-quarters of companies expect to offer this type of plan as an option for 2015, up from 63% in 2014. And 23% say it will be the only option, Towers Watson found.

While premiums on high-deductible health plans are typically 10% less than those of more traditional PPO plans, according to data from the Kaiser Family Foundation, co-insurance doesn’t kick in until you’ve paid much more out of pocket.

Read the full article here.

Contact Steven G. Cosby, MHSA with questions or to request more information and to schedule a healthcare plan evaluation, savings analysis or group plan solution for your company.

High Health Plan Deductibles Weigh Down More Employees

Anita Maina was working on an arts and crafts project she found on Pinterest — creating a table out of wood and cork — when she ripped off a fingernail while removing staples from a piece of wood.

“It is one of those things that really hurt, and I thought I should go to urgent care,” said Ms. Maina, 27.

But she ultimately skipped the visit since she had not met the $6,000 deductible on her health plan, and she knew she probably did not have much left in her health savings account, a type of tax-advantaged savings vehicle that is often used with high-deductible plans to help defray out-of-pocket costs.

Read the full article here.

Contact Steven G. Cosby, MHSA with questions or to request more information and to schedule a healthcare plan evaluation, savings analysis or group plan solution for your company.

Law Removes Deductible Limits for Small-Group Plans

President Barack Obama signed into law on April 1, 2014, the Protecting Access to Medicare Act. Although the main thrust of the bill is to prevent double-digit cuts in Medicare reimbursement to doctors from taking effect this year, tucked away inside the legislation was an important change to an Affordable Care Act (ACA) provision affecting group plans for small employers.Section 213 of the law now eliminates deductible limits imposed under the ACA for small-group market employer health plans. The new law, which took effect immediately, will allow more flexibility for plan designs.

Read full article here.

Contact Steven Cosby with questions or to request more information and to schedule a healthcare plan evaluation, savings analysis or group plan solution for your company.

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Tag: high deductible health plan

Applicability of the Embedded MOOP to Large Group and Self-Funded High Deductible Health Plans

2016 HSA Contribution Limits and Minimum Deductibles

The Biggest Healthcare Benefits Decision You’ll Have to Make This Year

High Health Plan Deductibles Weigh Down More Employees

Law Removes Deductible Limits for Small-Group Plans

Contact Steven Cosby

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