Health Care Reform Strategies Iowa Superintendents Finance & Leadership Consortium (ISFLC) February 13, 2013 Outline – Healthcare Reform Market Developments Strategies that Work Employer Requirements ©Copyright 2013 by Mark J. Becker & Associates – All Rights Reserved 2 Market Developments ©Copyright 2013 by Mark J. Becker & Associates – All Rights Reserved 3 #1: The Rules Change… Employer Mandate Individual Mandate Guaranteed Availability •Penalties apply for insufficient coverage. •Penalties apply for lack of coverage. •Incentives/subsidies •Limitations due to Pre-Existing conditions are removed. Most large employer, 200+ employees, will not likely find it financially feasible to exit group health benefits. Income levels weigh in on subsidy/incentives. Removes Pre-X for individual and group insurance. Pricing & Products are not issued for 2014. Medicaid Expansion Plan requirements - ongoing Public Exchanges and COOPs still in development. ©Copyright 2013 by Mark J. Becker & Associates – All Rights Reserved 4 #2: The Prices Change… Health Insurance Costs By Gender & Age Using Actual Individual Medical Rates for 2012 (Iowa Based Rates) Monthly Individual Rates (Non-Smoker) $1,600 $1,400 $1,200 $1,000 $800 $600 $400 $200 $18 & Under 23 28 33 38 43 48 53 58 63 Age Category Single Male Single Female Married + 2 Kids ©Copyright 2013 by Mark J. Becker & Associates – All Rights Reserved 5 What Direction to Take? …Strategies that Work ©Copyright 2013 by Mark J. Becker & Associates – All Rights Reserved 6 Strategies that Work 1. Collaboration 2. Analytics 3. Risk Management 4. Behavioral Change 5. Repositioning ©Copyright 2013 by Mark J. Becker & Associates – All Rights Reserved 7 1. Collaboration Reform/create an effective team. An Insurance Advisory Committee - An often overlooked and under utilized resource within any employer. The effective use of a dedicated team with diverse stakeholders from your District can be the key to: Cost management Benefit selection Value based change Employee satisfaction Bargaining …and more. Consider the “playbook” from Ankeny CSD… ©Copyright 2013 by Mark J. Becker & Associates – All Rights Reserved 8 The Process Overview • Task – Ensure equitable representation of all certified and non-certified staff as it pertains to benefits. • Purpose – The purpose of the Insurance Advisory Committee is to serve as an advisory body and accept some fiduciary responsibility to School officials as it pertains to the selection, management, and design of designated employee benefits. • Desired Outcome – provide input towards the efficient and effective use and delivery of designated employee benefits. Your Logo ©Copyright 2013, Mark J. Becker & Associates, LLC 9 The Process Keys for Success Survey Stakeholders • Gain input • Identify action items/need Create Committee • Keys to Success • Unbiased Approach • Fiduciary Responsibility • Common Good • Purpose, Principles, Role Implement/Manage Change Hire Consultant • Targeted Objectives • Measurable Goals • Mutual Benefit • Strategic Orientation • Analytics/Insight • Educate • Process/Results Driven • Advocacy/Representation Your Logo ©Copyright 2013, Mark J. Becker & Associates, LLC 10 The Process Cumulative Changes Managed Change Strategic Change Insufficient Change ©Copyright 2013, Mark J. Becker & Associates, LLC 11 2. Analytics “You can’t manage, what you can’t measure…” Identification Quantification Modeling Solving ….a problem, solution, conditions through measuring and nesting organization strategy, mission, vision into Key Performance Indicators ©Copyright 2013 by Mark J. Becker & Associates – All Rights Reserved 12 Analytics/Metrics Expanded Some examples of Benefit Metrics include: Cost per FTE Trend & Regressions Diagnostic categories Bio-metrics Rx Measures PTO integration with Disability Employee premium sharing versus plan design cost sharing ©Copyright 2013 by Mark J. Becker & Associates – All Rights Reserved 13 3. Risk Management Insurance is a tool to transfer/accept risk If you don’t know your risk, how do you know what your insurance needs are? Some benefits do not need insuring… ©Copyright 2013 by Mark J. Becker & Associates – All Rights Reserved 14 Risk Evaluation Risk Analysis: Key Questions: Is your group a super/sub-standard Risk? Risk Tolerance What can you afford/absorb? What do you need to transfer/retain What is your contractual, financial, philosophical & social obligation? Risk Tools ©Copyright 2013 by Mark J. Becker & Associates – All Rights Reserved 15 Risk Tools Financial Tension – Sharing risk with employees through Plan Design and Premiums (CDHP’s, etc.). Risk Transfer – reinsurance contracts (self-insured) and pooling points (fully-insured) Funding – reassessing insurance vs. non-insurance based benefits ©Copyright 2013 by Mark J. Becker & Associates – All Rights Reserved 16 Risk Transfer High Cost Too Little Protection Cost Curve Too Much Protection Least Cost ©Copyright 2013 by Mark J. Becker & Associates – All Rights Reserved 17 Funding Funding Arrangements/tools: Funding methods shift - risk , timing, & cost Financial and Legal Administrative contracts vary in legal risk accepted/transferred. ©Copyright 2013 by Mark J. Becker & Associates – All Rights Reserved 18 The Continuum of Funding Alternatives Fixed Costs Insured 100% Pooled Transfer of Financial & Legal Risk Minimum Premium Variable Cash Flow Self-insured ©Copyright 2013 by Mark J. Becker & Associates – All Rights Reserved 19 4. Behavioral Change Wellness Initiatives – Health screening, smoking cessation, weight control programs, etc. (Accountability Measures) Value-Based Benefits – Waiving or lowering cost sharing for preventive and chronic conditions. (Steerage Measures) Employee Education – Improve the amount and quality of data available on health care costs and quality outcomes measurements. (Education Measures) ©Copyright 2013 by Mark J. Becker & Associates – All Rights Reserved 20 5. Repositioning Sharing – philosophical/cultural Open Enrollment versus annual election Cash out/waiver options How much does/should the Employer pay versus Employee? Premium or Plan Design Premium sharing socializes the cost equally Plan design individualizes the cost Variable (coinsurance) vs fixed components (copays/deductibles) Tiering of Rates To help one tier pay less, another tier must pay more - algebra Spousal Carve-out – how much to pay for another employers employee? ©Copyright 2013 by Mark J. Becker & Associates – All Rights Reserved 21 5. Repositioning Additional Strategic Considerations Par-Contracts – expand upside, reduce downside Reserving Pay or Play modeling New Markets (i.e. Exchanges) Avoiding/Embracing ACA fees/penalties Expected pricing shift due to community rating Cadillac Tax avoidance Various Fees Etc. ©Copyright 2013 by Mark J. Becker & Associates – All Rights Reserved 22 Strategies that Work 1. Collaboration 2. Analytics 3. Risk Management 4. Behavioral Change 5. Repositioning ©Copyright 2013 by Mark J. Becker & Associates – All Rights Reserved 23 Employer Requirements ©Copyright 2013 by Mark J. Becker & Associates – All Rights Reserved 24 Patient Protection and Affordable Care Act Compliance – • For the most part, the burden of compliance has first fallen to Government entities, the health care industry, and insurance vendors. • For example, insurance vendors have, and will continue, to prompt group customers on compliance requirements when/where the burden falls on the vendor. • Fully-Insured: To date, many of the 2010-2012 required ACA provisions have been prompted by and implemented by insurance vendors for their fullyinsured groups. • Self-Insured: To date, most insurance vendors have also notified self-insured groups of required provisions….however implementation of such is not always included and the burden falls to the self-insured plan sponsor. ©Copyright 2013 by Mark J. Becker & Associates – All Rights Reserved 25 PPACA Fees Imposed on or Passed to Employers 2013: • Patient-Centered Outcomes Research Institute (PCORI) Trust Fund: Establishes a research fee to be assessed from all health plans including retiree-only plans which are generally exempt from most PPACA requirements. Fees are due by July 31, 2013 for calendar year plans. For fiscal year plans ending before October 1, the first fee is due by July 31, 2014. Employers will be assessed this annual fee that begins as $1 times the average number of covered lives. The fee increases the following year to $2 and is indexed thereafter. Four methods for calculation are available. Plan sponsors and issuers must report the fees under Code Sections 4375 and 4376 on Form 720. Most insurance vendors will incorporate the fees into the rates and file Form 720 for fully-insured plans. 2014: • Transitional Reinsurance Fee: Established to help stabilize premiums for coverage in the individual market during the first three years of exchange operations. Designed to mitigate the potential impact of adverse selection resulting from a large pool of previously uninsured individuals seeking coverage. HHS estimates the fee for 2014 to be $5.25 per member per month which is $63 annually for each covered employee, spouse and dependent. HHS will require enrollment information to be submitted (by insurers and third party administrators) by Nov. 15, 2014 and will notify them within a month of contributions due, which must be paid within 30 days of notification. ©Copyright 2013 by Mark J. Becker & Associates – All Rights Reserved 26 PPACA Fees Imposed on or Passed to Employers 2014: • Annual Fee on Health Insurance Companies “Users Fee or Insurance Fee”: Beginning in 2014, health insurance companies with net premiums exceeding $25 million will pay an annual fee expected to raise a total of $60 billion thru 2019. The fees begin at $8 billion in 2014 and are assessed based on an insurance company’s market share and are non-deductible for federal tax purposes. These fees are the responsibility of the insurance carrier to pay; however, they are expected to be passed along to both grandfathered and non-grandfathered small groups and fully-insured large group customers. At this time the fee expected to be passed on to employers with Wellmark insurance is approximately $7 - $9 per member per month. Other carriers may be applying the fee using different calculation methods such as a percent of annual premium. The amount of the fee from carriers will differ since market share differs. Employers need to be aware and include this in their budget setting process. ©Copyright 2013 by Mark J. Becker & Associates – All Rights Reserved 27 Patient Protection and Affordable Care Act 2014: Health Insurance Premium and Cost Sharing Subsidies: Beginning January 1, 2014, various refunds and tax credits become available to eligible individuals. Families with incomes between 133-400% of the Federal Poverty Level (FPL) can use such monies to purchase insurance through the Exchanges. Subsidies are available to those with incomes up to 250% of the FPL. Tax credits and subsidies will not be available to individuals who have “affordable” employer sponsored coverage available to them that also provides “minimum value.” Similarly, an employer will not be subject to a penalty tax if it offers to full-time employees “affordable” health coverage that provides “minimum value”. Affordable = Cost of coverage to the employee does not exceed 9.5% of the wages the employer pays that employee as stated in Box 1 of the W2; affordability test applies to single coverage on the lowest-cost plan option available to the employee. Coverage may also be deemed affordable if it satisfies either of two other design-based safe harbors. Minimum Value = The plan covers at least 60% of the total allowed cost of benefits expected to be incurred under the plan. Employers can input plan design data into actuarial value calculators that the HHS is making available in order to determine if the plan is providing minimum value. Health Insurance Exchanges: Effective January 1, 2014, the State exchanges are to be operational and available to individuals and small employers with up to 100 employees. ©Copyright 2013 by Mark J. Becker & Associates – All Rights Reserved 28 Patient Protection and Affordable Care Act 2014: Employer Shared Responsibility (pay or play): Effective January 1, 2014, a fee is imposed on employers with more than 50 employees (using an equivalent for part-time employees) that fail to offer coverage to all full-time employees (defined as employees who work an average of at least 30 hours/week). The fee is $2,000 per full-time employee, excluding the first 30 employees. An employer who offers coverage to all fulltime employees could also be subject to a fee if the coverage is not “affordable” or does not provide a “minimum level” of coverage. In this case, the fee is the lesser of (a) $3,000 for each full-time employee who receives a premium tax credit for coverage purchased on the exchange or (b) $2,000 for each full-time employee excluding the first 30 employees. Determining Full Time Employees: • A teacher or another employee working an average of at least 30 hours/week during the school year is considered full-time. Count actual hours worked and all periods of paid leave. Summer breaks or other periods of unpaid leave generally cannot reduce the average hours they work during the school year. • Count actual hours worked for substitute teachers. If they work an average of at least 30 hours/week during the school year then they will be considered full-time. ©Copyright 2013 by Mark J. Becker & Associates – All Rights Reserved 29 Patient Protection and Affordable Care Act 2018: • Tax on High-Cost Insurance: Commonly referred to as the “Cadillac Tax” and effective January 1,2018. This is an excise tax on employer-sponsored health plans that have expenses exceeding $10,200 for individual coverage and $27,500 for family coverage. ©Copyright 2013 by Mark J. Becker & Associates – All Rights Reserved 30 Cadillac Tax Example Illustrative Health Insurance Premium Projections for Family Coverage Assuming Average Growth Rate of 7.3% from 2012-2020 ©Copyright 2013 by Mark J. Becker & Associates – All Rights Reserved 31 IN CONCLUSION……. 1. Engage in strategies that work. 2. Reposition as necessary. 3. Check your progress toward compliance. Sources: Quarles & Brady LLP – “Health Care Reform Pay or Play Guide”; via the International Foundation of Employee Benefits National Institute For Health Care Management – “The Challenges of Pricing Health Insurance for the 2014 Exchanges” Truven Health Analytics – “Modeling the Impact of Pay or Play Strategies on Employer Health Costs” Henry j. Kaiser Family Foundation – “Focus on Health Reform” Keri K. Farrell-Kolb; Attorney at Law, Nyemaster Goode, P.C. Mark J. Becker & Associates, LLC – proprietary analytical tools ©Copyright 2013 by Mark J. Becker & Associates – All Rights Reserved 32 Thank you! Mark J. Becker President Mark J. Becker & Associates, LLC Keri K. Farrell-Kolb Attorney at Law Nyemaster Goode, P.C. Brenda J. Plantz Assistant Vice President Mark J. Becker & Associates, LLC Mark J. Becker & Associates, LLC 5501 NW 86th St., Suite 700 Johnston, IA 50131 515-273-5140 www.MJBAconsulting.com ©Copyright 2013 by Mark J. Becker & Associates – All Rights Reserved 33