All posts by Pia Brown

About Pia Brown

Pia has worked in the Employee Benefits arena for more than 16 years. Since joining Ovation Benefits in 2006 as a Senior Account Manager, she has progressed to Managing Consultant and now leads a team in consulting, design, and execution of Employee Benefit Programs that support and enhance each individual employer’s business strategy. Known for her shoot from the hip, consultative approach, Pia consistently helps move strategy forward. Together with her team, Pia supports employers that want more than “just benefits” for their business, their employees and their families. Pia began her career at Anthem Blue Cross Blue Shield in their rotational internship program, spending time in provider relations, marketing, member services, underwriting, sales and account management. She was a Team Lead in the Major Account Sales unit, specializing in large employer group health, dental and ancillary program designs. Pia completed her Certified Employee Benefit Specialist (CEBS) designation from the International Foundation of Employee Benefits and Wharton School of Business in 2010. She lives in Farmington with her family, including two daughters, Abby, five, and Margaret, 18 months, who keep her lovingly occupied. When there is free time, she enjoys literature, law and spending time with friends and family.

Avoid Surprises – Employers Need to Double Check Their ACA Penalty Exposure

We are five years into our ACA compliance journey. Dependent children to age 26? Check. Preventive care covered at 100%? Check. No dollar maximums? Check. Understanding market reforms? Check.  Since we are heading toward the 2014 tax year reporting due date, state marketplaces have issued their 1095-A’s for individual mandate reporting and are also issuing appeal letters to employers for 2015.

In addition, the 6055 and 6056 reporting requirements (which will support mandate compliance and subsidy substantiation) are fully underway and the first round of reporting is in less than 12 months. Plan sponsors are re-reviewing the details of the Employer Shared Responsibility (ESR) provisions — and some are making a startling discovery. Continue reading Avoid Surprises – Employers Need to Double Check Their ACA Penalty Exposure

Compliance Update: Reporting Requirements

Action required*

2015 is right around the corner and while we have provided a summary of what is coming down the pike (2014 ACA Compliance Checklist) you will want to pay extra attention to the Employer Shared Responsibility Provisions (a.k.a. Pay or Play) and the associated Reporting Requirements. You may recall that the reporting requirements and their complexity drove the delay of “Pay or Play” for 2014, since the intent of the reporting was to streamline the management of both the individual mandate, employer shared responsibility and the status of subsidy eligibility in the state marketplaces – Quite a broad reach! In light of the complexity of the new information reporting requirements, employers should take note and review the following.

SUMMARY:   The new reporting system will be similar to the current Form W-2 reporting process. A health coverage information return (Form 1095-B or 1095-C) must be provided to each applicable employee, and then these returns will be submitted to the IRS via a single transmittal form (Form 1094-B or 1094-C) Continue reading Compliance Update: Reporting Requirements

2 Crucial Responsibilities Self-Insured Employers Need to Act on Now

Employers who offer a self-insured medical plan now have two additional responsibilities: 1) Submitting for the Transitional Reinsurance Fee by November 15, 2014, and 2) Applying for an ACA and HIPAA Health Plan Identifier (HIPD) Number by November 5, 2014 or for “small plans” 2015.

Transitional Reinsurance Program Requirements

1) The Transitional Reinsurance Program was created by the Affordable Care Act section 1341 to help stabilize premiums in the individual market until 2016 by collecting $25 billion in fees from group health plans to partially reimburse insurers who cover high-cost individuals in the newly formed state marketplaces. Recently Aetna announced a likely $50M from the program to cover their additional risk: , and CTs Insurance Department rejected Anthem’s proposed individual and small business rate hikes due to not having enough of an offset for likely ACA reinsurance funds:

The Transitional Reinsurance Program Fee applies as of January 1, 2014 to both insured and self-funded “major medical” plans regardless of the plan year or policy year. (Guidance issued late last year will exempt certain multi-employer self-funded and self-administered union plans from the reinsurance fees in 2015 -2016.)

So what do you need to do as a self-funded plan? Continue reading 2 Crucial Responsibilities Self-Insured Employers Need to Act on Now

2014 Is Right Around The Corner – Arm Your Employees With Information (And Keep Them From Flooding Your HR Office)

With October 1st just past and January 1, 2014 right around the corner, a new wave of attention is being focused on health care reform, the Marketplaces, and the future of ACA. New options, new coverages, new eligibility rules, and sometimes misleading or half-truths in the media create uncertainty and confusion. Whatever your political leanings, the need to level set some basic information is key to setting a clear path and clearing through the clutter for your employees.

HC-Reform1-460x172Whether your philosophy is to “inform and over-inform” or to “keep it to the bare facts,” I recommend implementing a robust communication plan. Not only will you be viewed as well-versed in these challenging topics, you will also be serving to reduce employee stress about the multitude of changes and choices that lie ahead. Consider communicating these topics the way you would ramp up communications for open enrollment. Create posters, emails and payroll stuffers by utilizing the language I’ve suggested below in part or in whole:

Health Care Reform Overview

The Health Care Reform law, officially known as the Patient Protection and Affordable Care Act, was signed by President Obama in March 2010. The law is intended to expand access to affordable quality health care for Americans.

The law will be implemented over a 10-year period. Several rules of the law take effect in 2014. Some things may affect you and your family while others may not.

What’s Taken Effect So Far?

Here is a quick review of what has taken effect so far as a result of the health care reform law.  For more information, review the interactive timeline on or visit this link.

• Children Covered to Age 26 – Your dependent children up to age 26 can be covered under your medical plan, even if they are married, not living with you or not financially dependent on you.
• Summary of Benefits and Coverage (SBC) and Uniform Glossary – During each year’s enrollment, you will receive a Summary of Benefits and Coverage in paper or electronic form with information about our plan in a standard format so you can compare our plan to other coverage such as your spouse’s plan.
• W-2 Reporting – Each January, we will report the total value of your medical plan for the previous year on your W-2 tax form. This is for your information only and does not affect your income or taxes.
• No Lifetime Maximum – There is no lifetime dollar limit on the amount your medical plan will pay for “essential health benefits.” This refers to a set of benefits including the 10 general categories listed below. All plans may not include or cover all of these categories. However, for those items that are included, that plan cannot place lifetime dollar limits on those benefits.

Essential Health Benefits 10 General Categories:
1. Ambulatory patient services
2. Emergency services
3. Hospitalization
4. Maternity and newborn care
5. Mental health and substance abuse disorder services, including behavioral health treatment
6. Prescription drugs
7. Rehabilitative and habilitative services and devices
8. Laboratory services
9. Preventive and wellness services and chronic disease management
10. Pediatric services, including oral and vision care

• Additional Medicare Taxes – Individuals earning more than $200,000 and couples earning more than $250,000 began paying additional Medicare taxes in 2013.
• Preventive Care – Preventive care services like annual physicals and immunizations are covered at no additional cost to you. Effective August 1, 2012, non-grandfathered plans were required to cover additional women’s preventive services with no coinsurance, copays or deductibles, including certain health screenings, breast-feeding equipment and supplies, and contraceptives.
• Doctor Choice – If your plan requires you to choose a primary care doctor, you can select a general practitioner, family practitioner, internal medicine specialist or pediatrician. Women can also visit an obstetrician/gynecologist without a referral.
• Emergency Care – Emergency room services from any hospital are paid at the in-network level – even if the hospital isn’t in our plan’s network.
• Prescriptions for OTC Drugs – You must have a prescription to pay for most over-the-counter drugs from a Health Savings Account, Health Reimbursement Account or Flexible Spending Account.
• Flexible Spending Account Annual Contributions – The maximum amount you can contribute to a Health Care Flexible Spending Account is $2,500 per year.
• Health Savings Account Penalty – If you use your Health Savings Account for purchases not listed as eligible health care expenses under the federal tax code, you will pay a 20% penalty on those purchases.

Health Care Reform in 2014 and Beyond
You may have read or heard about some of the health care reform rules coming in the future. From the new Health Insurance Marketplaces to new requirements for having medical coverage, some significant parts of the law are taking effect in the coming months. To understand how health care reform may or may not impact you and your family, consider visiting for more information.

The Individual Mandate
A new requirement called the individual mandate is taking effect on January 1, 2014. All U.S. citizens and legal residents, with a few exceptions, are required to have “minimum essential coverage.” Coverage under one of our medical plans will satisfy this requirement. Other types of coverage that meet the individual mandate include plans provided by another employer, Medicare, Medicaid or individual health insurance.

The Exchange Marketplace
You may have heard about Health Insurance Marketplaces, or Exchanges, that all states are scheduled to open this fall. Marketplaces are being developed as new options where people can compare and purchase standard health insurance plans.

Federal subsidies may be available to assist low to moderate income individuals in paying the premium for health insurance purchased through the new Health Insurance Marketplaces. Eligibility for a subsidy is based on income. However, individuals who are eligible for employer-sponsored coverage that is “affordable” and provides “minimum value” are not eligible for the subsidy.

Coverage under policies purchased through the Marketplace can begin as early as January 1, 2014, and individuals can start enrolling on October 1, 2013. Connecticut’s Marketplace is AccessHealthCT

The Exchange Marketplace Notice
As required by the health care reform law, we will be providing/have provided you with a notice that contains information about the new Health Insurance Marketplace.

There are several reform-related benefit changes taking effect in 2014, including:

• No Pre-existing Condition Limits – No one will be denied coverage based on a pre-existing condition.
• No Annual Dollar Limits – There are no annual dollar limits on the amount our plan will pay for each year.
• Coverage Waiting Period – The waiting period before coverage begins will not be more than 90 days.
• Coverage for Clinical Trials – If you participate in a clinical trial, our plan will cover routine patient costs for care you receive as part of the clinical trial.

My hope in providing you the information above is to arm you with the most important information that you should be communicating with your employees, in language that is easily understandable.  Your goal as an advisor for your employees is to clear through the clutter for them, and give them the best information possible so that they can be educated consumers of their health care. If you utilize the above content in a well thought-out communication plan, you deliver it in bite sized, easily understandable pieces, and you do it consistently, then the visits to your office should dwindle.

This post is for general informational purposes only and is not intended for and should not be used as legal or tax advice. While we have attempted to provide current and accurate information, users should seek professional advice from their legal, tax and benefit plan advisors.