Back to School! The ABCs of SBCs

The ABCs of SBCsIt’s that time of year for many employers: fall open enrollment! That means many administrators of group health plans (those up for renewal at this time of year) are working to provide Summary of Benefits and Coverage (SBC) to their eligible individuals. (Technically, for insured plans the insurer is responsible for providing an SBC to the employer within seven days after the employer completes an application.  The insurer and the plan administrator are each responsible for providing the SBC to participants, but only one of them needs to actually do it – they need to work out who will do the distribution.  For self-funded plans, the plan administrator is responsible for providing the SBC.  The plan administrator can hire others, like its TPA, to help, but the plan administrator is ultimately responsible.) Assuming you have determined who is responsible, it is a good time to review all the latest requirements (including those independent of renewal dates) to be sure you fulfill this obligation correctly and avoid penalties. SBCs must be provided: 

  • At open enrollment
  • At renewal if there is no open enrollment
  • At initial enrollment 
  • At special enrollment
  • With a material mid-year change 

While the obligation to issue an SBC applies to all employers, regardless of size or type (private, government, not-for-profit)—including grandfathered plans—it primarily covers medical (PPO, HDHP, HMO, etc.) coverage and is not needed for the following: 

  • Stand-alone dental and vision benefits (stand-alone means these benefits are elected separately from medical and have discrete premiums)
  • Health FSAs unless the employer makes a significant contribution
  • Health savings accounts (HSAs), although the high-deductible health plan will need an SBC; the HSA can be mentioned as a source of funds to meet deductibles, coinsurance, etc. if desired
  • Hospital indemnity or specified illness coverage
  • Long-term care, disability or accident coverage
  • Retiree-only plans 

Remember that you must use the standard format prescribed by the regulatory agencies for the SBC. UBA offers a highlights document with a great summary of what and what not to include, alternate language requirements, electronic delivery guidelines and more. Make sure you: 

  • Verify who will prepare the SBC (insurer, TPA, employee(s), advisor) – and make sure that this person knows what is expected of them. (See the UBA SBC Frequently Asked Questions document for detailed information on instructions and templates.)
  • Verify the manner of distribution (paper or electronic) for different types of participants
  • Work through coordinating information if some benefits are provided by other vendors (such as prescription drugs or managed behavioral care)
  • Determine whether a non-English version of the SBC will be needed (see the UBA highlights document for a link to the list of the impacted counties)
  • Ensure that newly-eligible employees receive the SBC or notification of SBC availability with their application materials
  • If SBCs are provided electronically, implement a process to provide paper SBCs within seven days after they are requested

If you aren’t sure how to handle vision benefits, HRAs, EAP, wellness programs, HSAs, FSAs, carve-outs, information on premiums/contributions or how to complete the coverage examples or reconcile your plan terms with the glossary, view the UBA SBC Frequently Asked Questions document for detailed information.

So why does this process seem so inflexible? The purpose of the SBC is to make it easier for employees to compare coverage options.  The regulatory agencies believe that consistent presentation will make it easier for employees to do side-by-side comparisons. We hope these latest UBA tools (SBC highlights and SBC Frequently Asked Questions) help make this process more bearable!

IRS Issues Proposed PPACA Reporting Rules

The IRS has issued the long-awaited rules on required reporting of minimum essential coverage (under Code Section 6055) and affordable, minimum value coverage (under Code Section 6056).  These rules will first apply to the 2015 calendar year, wit…

I’m Proceeding with Exchange Notices, but How Do I Complete the Form?

Exchange Notice formsBy Mick Constantinou, Advisor, Employee Benefits
Connelly, Carlisle, Fields, & Nichols, A UBA Partner Firm

A recent UBA blog outlined some compelling reasons why some employers are proceeding with the 10/1 exchange notices despite the postponement of the penalty. For those who are doing that, we’ve uncovered some glaring issues with the questions in the model Exchange Notices recently released by the Department of Labor.

In preparation for a recent seminar on health care reform, my colleague, benefit advisor Justin Treece contacted the DOL to clarify these issues. 

Part A (page one) of the notice is essentially a Q&A/marketing piece about the exchanges.  Part B (pages two and three) of the version for employers that currently offer group health insurance requires the employer to provide information about the health coverage offered to employees.

What happened to questions #1 and #2?

The Part B section of the notice begins with question #3 (Employer Name) and not #1. In its current version, there is no question #1 or #2 anywhere on the form. So the mystery begins.

When Justin contacted the DOL to be sure we were downloading the correct version, the DOL representative’s response was, “Well, that’s weird.” 

The DOL representative did confirm that this was the right form and that employers should proceed and ignore the incorrect numbering.

The form instructions state, “This information is numbered to correspond to the Marketplace application.”  Upon review of the current draft of the Exchange Application, Appendix A on page 9 and 10 of the 12-page application provides the tie to the Exchange Notice. Question #1 is “Employee name” and Question #2 is “Employee Social Security number” on both pages. The remaining questions 3 – 16 match the Exchange Notice. Mystery solved.

Can you explain the check box on Part B? Should I check the box?

On the same Part B page, the employer is advised as follows about a check box:

“If checked, this coverage meets the minimum value standard, and the cost of this coverage to you is intended to be affordable, based on employee wages.”

Considering that Minimum Value Plans have not been released for employer small groups, and many employers have non-calendar year renewals, how would it be possible for a small group employer to check this box as part of the October 1, 2013 notice?

When asked the question by Justin, the DOL representative did not quite understand. Justin clarified, stating that generally speaking, all employers with a current group health insurance plan do not currently have a Minimum Value Plan. 

When the DOL representative asked Justin if he wanted to change the form, Justin indicated that while this would be the most logical action, Justin doubted he had the authority to make such a change. The DOL representative confirmed Justin’s doubt and suggested that Justin speak to Health and Human Services (HHS) or local politician. 

So what should employers do?

While it is not completely clear on how employers should be completing Part B of the Exchange Notice, one benefits attorney has suggested that if it is the employer’s intention to offer Minimum Value Plans and make them affordable at their 2014 renewal, the employer should check the box to indicate this. It has also been recommended to leave questions 13-16 blank since they are optional and could potentially add confusion to the employer/employee communication regarding the exchanges. UBA has an expanded FAQ that provides additional detail on the notices and filling out the form.

Stand Out from the Crowd with Voluntary Benefits

Voluntary benefits imageWith many employers forced to move employees to part-time schedules, send employees to exchanges, drop spouse/family coverage—or coverage altogether, and/or increase employee costs, employers can’t necessarily rely on their health benefits to attract and retain employees. With everyone trying to thread the needle on minimizing penalties, maximizing tax benefits, controlling health costs, and helping employees qualify for subsidies, let’s face it: the health plan may not be your hallmark anymore. So polices like flextime, corporate and social responsibility charters and voluntary benefits may become the cornerstones of your recruitment and retention strategy. UBA took a preliminary look at voluntary benefit trends in its Ancillary Products Survey, which indicates vast differences in voluntary benefits offered by employer size, region and industry.

Employees these days are more diverse than ever and because of this, each employee has their own unique needs. Ancillary benefits provide employers with the ability to meet these needs on a variety of levels. The first step in crafting a benefits package with voluntary or ancillary choices is knowing what others in your industry or area are offering. With comprehensive benchmarking data you can best identify cost-effective solutions that employees truly want. Auto and home insurance is a main staple in the Northeast for example. In larger companies, group term life is a must-have. Short term disability is critical in the manufacturing industry. Long term disability is most common in the retail industry and much less common in the construction/mining industry. While 2.7% of employers overall offer identity theft insurance, nearly 30% of larger employers include this in their package. Comprehensive data for your size, region and industry are the key to smart decisions.

To help employers develop a cost-conscious, yet effective voluntary benefits strategy, United Benefit Advisors (UBA), in conjunction with the Principal Financial Group® is hosting a free webinar, “Maximize Your Employee Benefit Dollars with Voluntary Benefits,” on Sept. 26 at 2 p.m. EDT. To receive the $149 discount for this webinar enter the code “UBAP” when registering. To register, visit: https://webinars.ubabenefits.com/tabid/1932/Default.aspx?wid=108. This webinar has been submitted to the Human Resource Certification Institute to qualify for 1.25 recertification credit hours.

How Large Employers are Responding to Health Care Reform

Peter Freska, CEBS
Benefits Advisor
The LBL Group, A UBA Partner Firm

health care reform and large employersI am constantly amazed when I hear that large employers (those with 100-plus employees, and especially those with 1,000-plus) do not know how they are going to handle health care reform yet. I recently read a post asking for information on how large employers are reacting to Health Care Reform. The responses to this post were very typical: adjust plans, reduce networks, change contributions and add additional cost controls like disease management, value based benefits or telemedicine. Or, what about charging for having a spouse with other plan options to come onto your employer based plan? Do these really help? Even having a spouse eligible for a plan presents a twist. Recall that under Health Care Reform, the definition of eligible dependents does not include a spouse. There is a reason for this: If a spouse is eligible then they cannot receive exchange subsidies.

So, what is an employer to do? Well, if they are a large employer – specifically a self-funded employer – they need to manage their plan; by this I mean the plan data. To do this a company must identify the real problems, and then apply real solutions. The key is to define near term cost-drivers. This is the crystal ball prediction that allows a plan to make the right changes at the right time. The typical model of census data along with medical and Rx has inadequate predictive power. Other data must be included to drive the predictability and manage near-term costs risk.

Why are employer based plans receiving double digit trends? The answers are simple: 1. Unknown cost drivers, and 2. Applying the wrong solution.  In order to make a difference a plan must uncover the right issues and implement the right solutions. If employers are to make a difference, or if the Board of Directors or trustees of the plans are to really understand why their plans cost continue to rise, they must think about health care the same way they think of other parts of their business. Does the typical large business have an understanding of those who consume their products? They had better! Why should health care be different? Employers spend millions of dollars each year to take care of employees and their families.

Keep this in mind: With the full implementation of health care reform upon us, private health insurance will continue to bear the costs in the health care system. The cost control answer for businesses is not with the typical clinical analytics, but with business intelligence analytics. This type of process will help large employers reduce claims cost and flatten their health care costs over the next three years.

Brushing Up On Your Employee Benefits Communication Skills

employee communication“The single biggest problem in communication is the illusion that it has taken place”. – George
Bernard Shaw

“Effective employee communication” is definitely a buzzword in the human resources industry. We all intuitively know communication is a good thing, but how many of us actually practice it on a daily basis? And let’s face it: Pressing deadlines always seem to trump establishing positive communication in the workplace. However, when a project or other initiative fails
due to a communication breakdown, we are all the first to say, “I wish I had communicated that more effectively.”

So why does communication fall so low on the priority list? It may have to do with the fact that we may need some tools to know how to communicate effectively. As much as we think it’s intuitive, it actually is a skill that needs to consistently be cultivated.

I recently ran across a TLNT article, Good Workplace Communication? It Means Good
Workplace Performance
, that provided three great tips to increase positive
communication:

  1. Providing feedback: Whether positive or negative, feedback is critical. Providing positive reinforcement for a job well done is just as effective as delivering constructive criticism. Also, providing the same feedback to each employee is not going to be as effective as catering your message for each individual employee.
  2. Understanding differences: With many of the positive sweeping changes in the civil rights arena, we tend to overlook the importance of cultural and generational differences in the workplace. However, these factors have a huge impact on your employees’ worldview, and more importantly, how they receive and filter information. Be aware of these filters and cater your message accordingly.
  3. Really listening: This may seem like a no-brainer, but are you a good listener? The article suggests listening as if there was going to be a pop quiz at the end of every conversation.

When it comes to benefits, I can’t think of a more crucial area that demands effective communication. In a recent survey by Colonial Life, only 23 percent of employees think their employers communicate their benefits very effectively. United Benefit Advisors will be hosting a webinar, presented by Touchpoints, that will share tips to help you create an effective communication strategy, and most importantly, execute that strategy and measure
the results.

The webinar, How Effective Communication Happens: Benefits Style!, will take place on Thursday, Sept. 12 at 2 p.m. EDT. To receive the $149 discount for this webinar, enter the code “UBATP” when registering.

The confusing swirl of PPACA regulations present a great opportunity to impress and retain your employees by ensuring they understand your benefits offerings.

Health Care Reform and the Balloonist

Hot Air BalloonBy Mick Constantinou, Advisor, Employee Benefits
Connelly, Carlisle, Fields, & Nichols, A UBA Partner Firm

In preparation for a recent keynote addresse at the Benefits Mania Conference on Health Care Reform and New Paradigms in the Benefits Renewal Process, the most challenging piece was deciding on how to open the presentation.

Public Speaking 101 indicates that speakers should open with a joke, but was joking about the ACA appropriate or professionally safe?

After searching the web for humorous stories and jokes related to “change management” – which is essentially what employers, individuals and our industry must embrace – multiple hits came up on a similar allegory about a man (or woman) in a hot air balloon.  There were a variety of versions of the allegory making it impossible to credit the original author of the story – so thank you to whomever was the originator of the allegory.

Regardless of the knowledge or beliefs – religious, political, social and economic – that have established a person’s or group’s paradigm, the balloonist allegory was not only appropriate but hauntingly familiar.

A man in a hot air balloon realized he was lost. He reduced altitude and spotted a woman below. He descended a bit more and shouted, “Excuse me, can you help me? I promised I’d be somewhere, but I don’t know where I am.”

The woman below replied, “You’re in a hot air balloon hovering approximately 30 feet above the ground. You’re between 40 and 41 degrees north latitude and between 59 and 60 degrees west longitude.”

“You must be an engineer,” said the balloonist. “I am,” replied the woman. “How did you know?”

“Well,” answered the balloonist, “everything you told me is, technically correct, but I’ve no idea what to make of your information, and the fact is I’m still lost. Frankly, you’ve not been much help at all. If anything, you’ve delayed my trip.”

The woman below responded, “You must be in management.” “I am,” replied the balloonist, “but how did you know?”

“Well,” said the woman, “you don’t know where you are or where you’re going. You have risen to where you are due to a large quantity of hot air.  You made a promise which you’ve no idea how to keep, and you expect people beneath you to solve your problems. The fact is you are in exactly the same position you were in before we met, but now, somehow, it’s my fault.”

Also read The Tomato Paradox of Health Care Reform and The Tomato Paradox Part 2: What’s Left on the Vine.

Happy and Well: Employee Wellness Under Obamacare

employee wellnessA recent article in Human Resource Executive Online shared a startling statistic: It takes about 16 years to realize a positive return-on-investment on employer-sponsored wellness programs. That’s a long time, and more importantly makes you wonder why we implement wellness programs at all? According to this article, it’s not so much about the health care dollars you gain back for your business with wellness programs, but more about how these initiatives can transform your company culture for the better.

Here’s a quick article excerpt:

“Edington believes wellness programs can’t save enough in healthcare costs to make a difference – ‘maybe $200 to $300, at best’ – but he thinks a wellness program can create shareholder value.

How? By increasing job satisfaction, happiness factors and creating a great place to work. By association, according to Edington, wellness programs raise employee loyalty, decreases turnover and increases creativity and productivity. And that’s good for the business’ bottom line.

Edington summarizes it this way: ‘Happiness [is] the new, ultimate metric.’”

While some may want to argue the concept of wellness program ROI, you can’t debate the fact that more than 75 cents of every health care dollar spent in the United States goes toward treating chronic diseases such as arthritis, asthma, cancer, cardiovascular disease and diabetes, according to the Centers for Disease Control and Prevention.

Regardless of an employer’s main reason for implementing a wellness program, it’s important to know the latest strategies when it comes to ensuring that they’re effective and PPACA-compliant.

Unum and United Benefit Advisors (UBA) are hosting two free webinars: “Health and Wellness and Employee Motivation: Making the Connection” on Aug. 27, 2013 at 2 p.m. ET, and “Legal Considerations When Developing an Employer-Sponsored Wellness Program” on Aug. 29, 2013 at 2 p.m. ET, that aim to address effective wellness program strategies and health care reform considerations.

 “Health and Wellness and Employee Motivation: Making the Connection” will prepare employee benefits and human resource managers to manage and consult upon the emerging issues related to the multigenerational workforce including productivity and motivation. The presentation examines the health care industry and its unique challenges in managing productivity due to the aging population, health reform, disengaged workers, and the need to mitigate the impact of the rising costs of healthcare among its own employees. To register, click here. Receive a $149 discount for this webinar, enter code UNUMUBA27 when registering.

To ensure that your wellness programs are PPACA-compliant, the webinar, “Legal Considerations When Developing an Employer-Sponsored Wellness Program,” will review new rules for wellness programs under health care reform. To register, click here. Receive a $149 discount for this webinar by entering the code UNUMUBA29 when registering.

Happy and Well: Employee Wellness Under Obamacare

wellnessA recent article in Human Resource Executive Online shared a startling statistic: It takes about 16 years to realize a positive return-on-investment on employer-sponsored wellness programs. That’s a long time, and more importantly makes you wonder why we implement wellness programs at all? According to this article, it’s not so much about the health care dollars you gain back for your business with wellness programs, but more about how these initiatives can transform your company culture for the better.

Here’s a quick article excerpt:

“Edington believes wellness programs can’t save enough in healthcare costs to make a difference – ‘maybe $200 to $300, at best’ – but he thinks a wellness program can create shareholder value.

How? By increasing job satisfaction, happiness factors and creating a great place to work. By association, according to Edington, wellness programs raise employee loyalty, decreases turnover and increases creativity and productivity. And that’s good for the business’ bottom line.

Edington summarizes it this way: ‘Happiness [is] the new, ultimate metric.’”

While some may want to argue the concept of wellness program ROI, you can’t debate the fact that more than 75 cents of every health care dollar spent in the United States goes toward treating chronic diseases such as arthritis, asthma, cancer, cardiovascular disease and diabetes, according to the Centers for Disease Control and Prevention.

Regardless of an employer’s main reason for implementing a wellness program, it’s important to know the latest strategies when it comes to ensuring that they’re effective and PPACA-compliant.

Unum and United Benefit Advisors (UBA) are hosting two free webinars: “Health and Wellness and Employee Motivation: Making the Connection” on Aug. 27, 2013 at 2 p.m. ET, and “Legal Considerations When Developing an Employer-Sponsored Wellness Program” on Aug. 29, 2013 at 2 p.m. ET, that aim to address effective wellness program strategies and health care reform considerations.

 “Health and Wellness and Employee Motivation: Making the Connection” will prepare employee benefits and human resource managers to manage and consult upon the emerging issues related to the multigenerational workforce including productivity and motivation. The presentation examines the health care industry and its unique challenges in managing productivity due to the aging population, health reform, disengaged workers, and the need to mitigate the impact of the rising costs of healthcare among its own employees. To register for this webinar, visit http://tinyurl.com/n4olw4s. Receive a $149 discount for this webinar, enter code UNUMUBA27 when registering.

To ensure that your wellness programs are PPACA-compliant, the webinar, “Legal Considerations When Developing an Employer-Sponsored Wellness Program,” will review new rules for wellness programs under health care reform. To register, visit: http://tinyurl.com/n2yca7h. Receive a $149 discount for this webinar by entering the code UNUMUBA29 when registering.

Help Your Employees Understand the Individual Mandate

individual mandate imagesWith all of the Patient Protection and Affordable Care Act (PPACA) regulations, the last thing employers want to do is worry about requirements that don’t apply.  One particular regulation that doesn’t necessarily concern employers is the individual responsibility requirement (also know as the individual mandate). 

And although the employer shared responsibility requirements have been delayed to 2015, the individual responsibility requirement is still scheduled to take effect in 2014. Under the individual mandate, most people residing in the U.S. will be required to have minimum essential coverage, or they will have to pay a penalty. Many individuals will be eligible for financial assistance, through premium tax credits (also known as premium subsidies), to help them purchase coverage if they buy coverage through the health insurance marketplace (also known as the exchange). 

Employers are not required to educate their employees about their individual responsibilities under PPACA, but providing information on this component of the law is just another way to help your employees understand all facets of health care reform.

United Benefit Advisors has developed a summary of individual mandate requirements that employers may find useful. The summary includes:

  • General information on the individual responsibility requirement;
  • Eligibility requirements for premium subsidies; and
  • Penalty exemptions.

To view this summary, click here.