Sunday, September 25, 2011

Weekend Update

Congress remains in session (notwithstanding plans for a recess this week) as the clock clicks down toward the end of the current federal fiscal year on Friday night. Unless Congress passes a continuing resolution before then, a government shutdown will occur on Saturday. Last Spring, OPM advised that the FEHBP would be status quo in the event of a shutdown due to  a lack of appropriations. Hopefully, cooler heads will prevail. Govexec's story is here.

Beginning in 2014, the Affordable Care Act imposes a $3,000 annual penalty on employers, including the U.S. Government, for each employee who cannot afford the employer's health insurance offering. Business Insurance reports 

The penalty would apply in cases where an employee’s health insurance premium contribution exceeds 9.5% of household income, making them eligible for federal premium subsidies to buy coverage through state insurance exchanges.
A safe harbor provision that the Internal Revenue Service unveiled this month for public comment to pass this health care reform law requirement affirmed what benefit experts had thought for some time: that the affordability test only will apply to employee or self-only coverage.
Group health care plans would be able to qualify for the safe harbor—shielding them from the $3,000 per employee affordability penalty—so long as the premiums employees are required to pay for self-only coverage in the least costly plan available to them does not exceed 9.5% of their wages.
Excluding dependent coverage from the affordability test in the IRS safe harbor was deliberate because the affordability requirement applies only to coverage of employees, experts say.

The IRS published this proposed guidance in IRS Notice No. 2011-73. The comment deadline is December 13, 2011.

The AMA News offers doctors advice on collecting co-payments and deductibles, which you wouldn't expect to be difficult. However, the article notes that
The American Medical Association's Code of Medical Ethics states that if a co-pay is a barrier to necessary care and creates financial hardship, physicians should forgive or waive it. The code also states that medical practices need to consider that routinely waiving co-pays may constitute fraud under state and federal law. Physicians may need to consult an attorney or other practice management expert to ensure that related policies are consistent with applicable regulations and with the requirements of insurer agreements.
FEHB plan brochures state that routine waiver of co-payments is an inappropriate practice.

The FEHBlog ran across this interesting web site about the U.S. Institute of Medicine's round table on value and science-driven care.

The FEHBlog inaccurately predicted that 2012 FEHBP premiums and the government contribution change would be announced last week. The FEHBlog has stopped making predictions, but will be watching

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