Last week I shared some of the key themes and priorities I have been hearing in my discussions with customers. The key themes were:
We need lower healthcare costs
We have to give our employees the best benefits we can afford
We need help with wellness
No administrative headaches, please.
Help me with health reform
In many of these same discussions, I am hearing that companies are starting to grow again, and about where and in many cases that growth is outside the U.S., which can put a little bit of a wrinkle in these top five priorities. Now, we are talking about solving these problems on a global scale, not just for domestic benefits.
Why global? While domestic U.S. benefits are still by far the biggest cost and biggest challenge for employers across the globe, we are not doing our job if we do not address these “Top 5” problems for employees regardless of which country or region of the world they are working. They are your employees, and the same problems persist.
It’s also about the great opportunity we have to help unite employees behind your strategy across the globe. If your growth plan calls for expansion in markets outside the U.S., shouldn’t we be able to leverage your global benefits budget to strengthen employee engagement and commitment to your core values and long term strategic vision, regardless of where employees work and live?
We think so.
Interested in learning more? Join us for an upcoming seminar, Developing an Integrated Global Benefits Strategy on Wednesday, October 3, 2012 from 3:00pm – 5:00pm.
Last week I made my debut here on the OvationNation blog with a post titled 10 Things Employers Must Know to Navigate the ACA: Part 1. I understand from our marketing department that my post was well-received, and in addition to receiving a high number of hits here on the blog, the post also made its way around the worlds of Twitter and LinkedIn. Who knew!
I do try to pare down information for our clients into digestable chunks of knowledge that they can really use, and that’s what I am attempting to do with this two-part series.
In Part 1 I outlined five of the things that I think employers need to keep in mind with regard to navigating the Affordable Care Act. Here are the last five:
6. 90-Day Limitation on Waiting Periods Public Health Service (PHS) Act section 2708, as added by the Affordable Care Act, provides that, in plan years beginning on or after January 1, 2014, a group health plan or group health insurance issuer shall not apply any waiting period that exceeds 90 days. PHS Act section 2704(b)(4), ERISA section 701(b)(4), and Code section 9801(b)(4) define a waiting period to be the period that must pass with respect to the individual before the individual is eligible to be covered for benefits under the terms of the plan. In previous regulations, the Departments defined a waiting period to mean the period that must pass before coverage for an employee or dependent who is otherwise eligible to enroll under the terms of a group health plan can become effective. Unlike Code section 4980H, PHS Act section 2708 does not distinguish between full-time and part-time employees.
In addition to requesting comments on the employer shared responsibility provisions, IRS Notice 2011-36 requested comments on behalf of the Departments regarding the 90-day waiting period limitation under PHS Act section 2708, including how rules relating to the potential look-back/stability period safe harbor method for determining the number of full-time employees under Code section 4980H should be coordinated with the 90-day waiting period limitation.
7. Women’s Health Preventive Care Enhancement: Employer group health plans that are not grandfathered will need to provide these additional no-cost preventive services for women for plan years beginning on or after August 1, 2012. (For calendar-year group health plans, this means compliance is required beginning January 1, 2013.)
In particular, the government has added the following eight categories of women’s services to the list of mandatory preventive services:
Gestational diabetes screening
HPV DNA testing
Sexually transmitted infection counseling
HIV screening and counseling
FDA-approved contraception methods and contraceptive counseling
Breastfeeding support, supplies and counseling
Domestic violence screening and counseling
8. FSA Limit of $2,500 effective 1/1/2013: Under the Patient Protection Affordable Care Act (PPACA), employee health FSA contributions will be limited to $2,500 annually effective for taxable years beginning after December 31, 2012. The $2,500 limit will be indexed to the consumer price index in following years to account for changes in the cost of living. Health FSAs continue to be subject to nondiscrimination testing.
Requires health plans to report the proportion of premium dollars spent on clinical services, quality, and other costs and provide rebates to consumers if the share of the premium spent on clinical services and quality is less than 85% for plans in the large group market and 80% for plans in the individual and small group markets.
Implementation: Requirement to provide rebates begins for coverage purchased in 2011, with the rebates issued to enrollees the year following (2011 rebates will be provided in 2012).
We know that this information can be overwhelming, and we are proud to have experts on our team to help employers navigate the “need to know” aspects of the ACA. We encourage you to contact us if you have any questions!
And don’t forget–on June 7th we are hosting a webinar on the HIPAA Privacy Rule.
Date: Thursday, June 7, 2012
Time: 11:00am to 12:00pm
Join Stacy H. Barrow, Associate, Proskauer, and Pia Brown, Consultant, Ovation, as they present a one-hour webinar that will cover HIPAA’s Privacy Rule.
Proskauer Health Reform Webinar: Impact on Employees
TUESDAY JULY 19, 2011
11:00 AM – 12:00PM
We are pleased to offer this free, one-hour webinar to our clients and prospects.
Hear up-to-date information from Stacy Barrow, Associate at Proskauer, Rose LLC, including latest updates, grandfathering, non-discrimination, age 26 coverage, claim reviews, appeals, rescission, and general health & welfare plan compliance including DOMA, GINA and DOL audits. Barrow is an Associate in the Labor & Employment Law Department and a member of the Employee Benefits, Executive Compensation and ERISA Litigation Practice Center and the Health Care Reform Task Force at Proskauer. Continue reading Register Today for Health Reform Webinar→