CCIIO Exempts HRAs From Applying for Annual Limit Waivers
The U.S. Center for Consumer Information and Insurance Oversight (CCIIO) has issued guidance with respect to the application of the existing annual limit waiver criteria to Health Reimbursement Arrangements (HRAs). This supplemental guidance exempts HRAs that are subject to the restricted annual limits as a class from having to apply individually for an annual limit waiver.
An HRA in effect prior to Sept. 23, 2010 is exempt from applying for an annual limit waiver for plan years beginning on or after Sept. 23, 2010 but before Jan. 1, 2014. These HRAs still must comply with the record retention and Annual Notice requirements to participants and subscribers set forth in the supplemental guidance issued on June 17, 2011.
The guidance can be found at: http://cciio.cms.gov/resources/files/final_hra_guidance_20110819.pdf.
HHS's Big Problem with the Federal Fallback Exchange
When the Department of Health and Human Services (HHS) released the first regulation providing guidance to the states on forming a health benefit exchange in July, one thing many health policy wonks noticed right away is that it contained no specifics on how a federal fallback exchange might work. Finally, last week a Politico report shed some light as to why HHS might be so reticent with the details.
HHS has virtually unlimited funding to help states create their own exchanges, but a quirk in the Patient Protection and Affordable Care Act (PPACA) is that it did not appropriate any funds to HHS for the federal government to develop its own infrastructure to fulfill the PPACA requirement to create and operate exchanges in all the states that do not establish their own. According to Politico, "A federal exchange will have the same authority states do to impose fees on insurance sold through the exchange once it is open for business. But there is no money coming in until people start purchasing insurance, and there is a great deal of work to be done to prepare to open the doors of federal exchanges."
Buck Releases HCR Impact Survey of Health Care Organizations
Some of the key findings from a newly released Buck Consultants national survey of healthcare organizations regarding the impact of health care reform:
- 79 percent of the survey respondents indicated that reform will increase health care costs in the country (with 43 percent indicating that costs will increase significantly); only 20 percent believe it will reduce costs.
- More than 70 percent believe the hospital industry and employer benefit plans will be worse off.
- 48 percent believe their families will be worse off, and only 21 percent believe they will be better off.
- 41 percent believe quality will decrease nationally, while 39 percent think quality will improve.
- 45 percent believe patients will be worse off versus 44 percent who believe they will be better off.
- 60 percent believe the country will be worse off because of health care reform, while 34 percent think it will be better off.
- 72 percent think health care reform will adversely affect employer health plans.
- 57 percent of the respondents lost grandfathering for some or all plans in 2011, and we anticipate that nearly 100 percent of employer plans will lose grandfathering by 2014.
- The primary reason (65 percent) for loss of grandfathering was that plan design changes were implemented with plan savings that exceeded the additional cost of complying with the health care reform requirements
- 75 percent expect cost increases of 1 percent or more due to reform in 2011.
- 58 percent expect higher costs due to reform in 2014.
- 71 percent expect higher employer costs due to reform long term.
- More than 90 percent of the survey respondents anticipate passing on some or all of these additional costs to employees through higher employee contributions or reduced coverage.
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