Guidance – Page 3 – Total Benefit Solutions Inc

Inflation Reduction Act: Limits Monthly Copayments for Insulin in Medicare

October 20, 2022September 8, 2022Ed MacConnell

Beginning in 2023, limits copayments to $35 per month per prescription for covered insulin products in Medicare Part D plans and for insulin furnished through durable medical equipment under Medicare Part B, with no deductible. For 2026 and beyond, limits monthly Part D copayments for insulin to the lesser of: $35 25% of the maximum fair price (in cases where the insulin product has been selected for negotiation) 25% of the negotiated price in Part D plans Please call your Total Benefit Solutions Medicare health insurance specialists with any questions or concerns at (215)355-2121.

What is the Marketplace?

October 19, 2022September 21, 2022Ed MacConnell

Shorthand for the “Health Insurance Marketplace®,” a shopping and enrollment service for medical insurance created by the Affordable Care Act in 2010. In most states, the federal government runs the Marketplace (sometimes know as the “exchange”) for individuals and families. On the web, it’s found at HealthCare.gov. Some states run their own Marketplace at different websites. Fill out a Marketplace application and you’ll find out if you qualify for lower monthly premiums or savings on out-of-pocket costs based on your income. You may find out if you qualify for Medicaid or the Children’s Health Insurance Program (CHIP). You can shop for and enroll in affordable medical insurance online, by phone,… Read More

Additional Guidance on New Prescription Drug Reporting Requirement

October 18, 2022September 20, 2022Ed MacConnell

As previously reported in 2021, Section 204 of the Consolidated Appropriations Act, 2021 (“CAA”) requires plan sponsors of group health plans to submit information annually about prescription drugs and health care spending to Centers for Medicare and Medicaid Services (“CMS”) on behalf of the Departments of Health and Human Services (“HHS”), Labor (“DOL”), and the Treasury (collectively, the “Departments”). The first deadline is December 27, 2022. CMS recently updated guidance related to this reporting requirements that proves some helpful clarification. Have any questions regarding this notice? Please contact your Total Benefit Solutions health insurance specialists today at (215)355-2121.

What is a premium?

October 14, 2022September 21, 2022Ed MacConnell

The amount you pay for your health insurance every month. In addition to your premium, you usually have to pay other costs for your health care, including a deductible, copayments, and coinsurance. If you have a Marketplace health plan, you may be able to lower your costs with a premium tax credit. When shopping for a plan, keep in mind that the plan with the lowest monthly premium may not be the best match for you. If you need much health care, a plan with slightly higher premium but a lower deductible may save you a lot of money. After you enroll in a plan, you must pay your first… Read More

Inflation Reduction Act: Requires Drug Manufacturers to Pay Rebates for Drug Price Increases Above Inflation

October 11, 2022September 7, 2022Ed MacConnell

Requires drug manufacturers to pay a rebate if drug prices increase faster than the rate of inflation (CPI-U) for: Single-source drugs and biologicals covered under Medicare Part B All covered drugs under Medicare Part D except those where average annual cost is <$100 2021 is the base year for measuring cumulative price changes relative to inflation The rebate amount is based on units sold in Medicare multiplied by the amount that a drug’s price in a give year exceeds the inflation-adjusted price Price changes are measured based on the average sales price (for Part B drugs) or the average manufacturer price (for Part D); these measures include prices charged in… Read More

Total Benefit Solutions, Inc appoints with Lasso Medicare Medical Savings Accounts Plans for 2022-2023 Open Enrollment Season

October 11, 2022Ed MacConnell

What is a Medicare Medical Savings Account (MSA) Plan? – A Medicare Medical Savings Account (MSA) plan is a type of Medicare Advantage plan that combines a high-deductible health plan with a medical savings account. Enrollees of Medicare MSA plans can initially use their savings account to help pay for health care, and then will have coverage through a high-deductible insurance plan once they reach their deductible. Medicare MSA plans can provide Medicare beneficiaries with more control over health care utilization, while still providing coverage against catastrophic health care expenses. Ask your Total Benefit Solutions, Inc. Medicare health insurance specialist of a Medicare Medical Savings Account could be worth considering… Read More

New Jersey New Poster Requirements

October 7, 2022October 7, 2022Ed MacConnell

On August 1, 2022, the New Jersey Division on Civil Rights (DCR) finalized regulations to increase the visibility and effectiveness of posters required by the State of New Jersey. Among other things, these regulations require employers to display posters informing people of their rights under New Jersey’s Law Against Discrimination (“NJLAD”) and Family Leave Act (“NJFLA”). The regulations went into effect immediately. The NJLAD protects New Jersey employees from discrimination in the workplace. It prohibits all employers in the State of New Jersey from discriminating against and harassing employees (and prospective employees) based on their protected status (including, but not limited to, race, national origin, age, sex, gender identification, sexual… Read More

Part D Senior Savings Model: Is there a cap on the number of units monthly to get the $35 copay?

October 7, 2022August 22, 2022Ed MacConnell

Generally, the maximum $35.00 copayment under the Model applies to one month’s supply of insulin. This may be limited by a physician’s prescription or by plan rules on drug dosage to ensure patient safety. Please note that if an enrollee uses multiple types of insulin or has multiple prescriptions for select insulins covered under the Model, each prescription would have a copayment of a maximum $35.00 for a one month’s supply. Have any questions or concerns regarding this notice? Don’t hesitate to call your Total Benefit Solutions Medicare specialists today at (215)355-2121.

What is an expected benefit Health Reimbursement Arrangement?

October 6, 2022September 1, 2022Ed MacConnell

An excepted benefit Health Reimbursement Arrangement (HRA) allows employers to finance additional medical care, like vision or dental coverage, coinsurance and copayments for individual health insurance coverage, short-term limited-duration insurance, or other health care costs not covered by their primary group plan. Excepted benefit HRAs cannot be used to reimburse individual health insurance coverage premiums, group health plans premiums (other than COBRA or other group continuation coverage), or Medicare premiums. However, an excepted benefit HRA can be used to reimburse premiums for individual health insurance coverage or group health plan coverage that consists solely of excepted benefits. This type of HRA, like the individual coverage HRA, allows rollover of unused… Read More

Inflation Reduction Act Requires the Secretary of HHS to Negotiate Medicare Drug Prices

October 5, 2022August 24, 2022Ed MacConnell

Modifies the current law “non-interference” clause to require the HHS Secretary to negotiate drug price with manufacturers for some drugs covered under Medicare Part B and Part D. Which drugs qualify for negotiation? The Secretary selects drugs to be negotiated from the 50 “negotiation-eligible” drugs with the highest total Medicare Part D spending and the 50 “negotiation-eligible” drugs with the highest total Medicare Part B spending. Which drugs are excluded from negotiation? “Negotiation eligible drugs” include brand-name drugs or biologics and exclude the following drugs: Drugs that have a generic or biosimilar available Drugs less than 9 years (for small-molecule drugs) or 13 years (for biological products) from their FDA-approval… Read More

Part D Senior Savings Model: Will there be a plan with higher premiums for insulin at a lower cost?

October 3, 2022August 22, 2022Ed MacConnell

The Part D Senior Savings Model allows drug manufacturers to offer their discounts in the coverage gap, even when a Part D plan enhances cost sharing. This allows plans to offer a fixed, consistent cost sharing on insulin. This structure is estimated to save enrollees who take insulin $446 in annual out-of-pocket costs. Part D sponsor plan premiums vary and beneficiaries should find a Part D plan that provides coverage they want at the lowest total annual cost, premiums and out-of-pocket costs combined. As always, please contact your Total Benefit Solutions Medicare health insurance specialists at (215)355-2121 with any questions or concerns.

Inflation Reduction Act: Establishing the Negotiated “Maximum Fair Price” for Medicare

September 30, 2022August 31, 2022Ed MacConnell

The upper limit for the negotiated price of a drug (the “maximum fair price”) is equal to the lower of: The drug’s enrollment-weighted negotiated price (net of all price concessions) for a Part D drug; The average sales price for a Part B drug; or A percentage of the non-federal average manufacturer price (i.e., the average price wholesalers pay manufactures for drugs distributed to non-federal purchasers), depending on FDA approval date: 75% for small-molecule drugs more than 9 years but less than 12 years beyond FDA approval; 65% for drugs between 12 and 16 years beyond FDA approval; and 40% for drugs more than 16 years beyond FDA approval Financial… Read More

Can consumers who qualify for COBRA continuation coverage opt out of it and get coverage through the Marketplace instead?

September 27, 2022September 1, 2022Ed MacConnell

Consumers who qualify for COBRA coverage can opt out of it and enroll in Marketplace coverage. However, voluntarily terminating COBRA continuation coverage does not make a consumer eligible for a Special Enrollment Period (SEP) based on loss of the COBRA continuation coverage. Note that all qualified enrollees eligible for COBRA continuation coverage can get the Marketplace subsidy, not just the employee who qualifies for the COBRA benefit, as long as they are not actually enrolled in the COBRA continuation coverage. Please contact your trusted Total Benefit Solutions health insurance specialists with any questions or concerns at (215)355-2121.

Final Rules Adopt Administrative Changes to the No Surprises Act

September 26, 2022September 22, 2022Ed MacConnell

On August 26, 2022, the Departments of Labor, Health and Human Services, and the Treasury (together, the “Departments”) published final rules on the No Surprises Act, making changes to the administrative duties of insurance carriers, HMOs, third-party administrators, out-of-network healthcare providers, and certain other entities responsible for the Act’s implementation. The new rules, which take effect on October 25, 2022, are narrow in scope, and include the following changes:• During processing of claims under the No Surprises Act, if “down-coding” occurs (i.e., the group medical plan alters or replaces the medical billing codes chosen by the out-of-network healthcare provider, resulting in a lower claim payment), then the final rules impose… Read More

What Insulin Drugs are Covered Under the Part D Senior Savings Model?

September 23, 2022August 18, 2022Ed MacConnell

Part D sponsors are required to include at least one vial and pen dosage form for each of the different types of Model insulins, where available – rapid acting, short-acting, intermediate-acting and long-acting – at a maximum $35 copay for a one-month supply through the deductible, initial coverage, and coverage gap phases of the benefit. Part D sponsors are encouraged to include additional insulin formulations, such as concentrated insulins, at the same $35 copay for a one-month supply. The Model doesn’t affect the cost sharing of insulin covered under Part B. For a full list of the insulin drugs covered by each plan, as well as which drugs are covered… Read More

Turning 26: Your Guide to Health Insurance

September 23, 2022Ed MacConnell

Turning 26: Your Guide to Getting Your New Health Insurance:https://totalbenefits.net/turning-26-your-guide-to-health-insurance/

2022 MLR Rebate Checks to Be Issued Soon to Fully Insured Plans

September 23, 2022September 22, 2022Ed MacConnell

As a reminder, insurance carriers are required to satisfy certain medical loss ratio (“MLR”) thresholds. This generally means that for every dollar of premium a carrier collects with respect to a major medical plan; it should spend 85 cents in the large group market (80 cents in the small group market) on medical care and activities to improve health care quality. If these thresholds are not satisfied, rebates are available to employers in the form of a premium credit or check. If a rebate is available, carriers are required to distribute MLR checks to employers by September 30, 2022. Click the link below to download the full bulletin.

Prescription Drug Provisions in the Inflation Reduction Act

September 21, 2022August 17, 2022Ed MacConnell

For the first time, requires the federal government to negotiate prices for some top-selling drugs covered under Medicare Requires drug companies to pay rebates if prices rise faster than inflation for drugs used by Medicare beneficiaries Eliminates 5% coinsurance for catastrophic coverage in Medicare Part D in 2024, adds a $2,000 cap on Part D out-of-pocket spending in 2025, and limits annual increases in Part D premiums for 2024-2030 Limits monthly cost sharing for insulin products to $35 for people with Medicare Expands eligibility for Medicare Part D Low-Income Subsidy full benefits Eliminates cost sharing for adult vaccines covered under Medicare Part D and improves access to adult vaccines under… Read More

Open Enrollment Tips!

September 20, 2022August 15, 2022Ed MacConnell

As always, please contact your Total Benefit Solutions health insurance specialists at today at (215)355-2121.

Understanding the Health Care Provisions in the Inflation Reduction Act

September 19, 2022August 16, 2022Ed MacConnell

The Inflation Reduction Act includes several landmark health care provisions that would lower prescription drug costs for people with Medicare, reduce Medicare drug spending and extend enhanced subsidies for Affordable Care Act marketplace coverage. On Thursday, August 11, a panel of KFF experts held a web briefing to explain these provisions and how they would affect people and federal health spending, followed by a Question and Answer session. Click here to open article and view Web Event video. The legislation for the first time would require the U.S. Secretary of Health and Human Services to negotiate directly with drug manufacturers over the price of some high-cost drugs in the Medicare… Read More

Medicare Creditable Coverage Part D notification requirements

September 15, 2022September 15, 2022Ed MacConnell

FROM INDEPENDENCE: Each year, the Centers for Medicare & Medicaid Services (CMS) requires plans that offer prescription drug coverage to their Medicare‑eligible employees, retirees, and dependents to notify them by October 15 as to whether that coverage is “creditable” or “non‑creditable.” What customers must do Customers must take the following steps to comply with this requirement: Review the materials provided to determine whether their prescription drug coverage is creditable or non‑creditable. Disclose to their Medicare‑eligible members (employees and their dependents) whether their prescription drug coverage is creditable or non‑creditable prior to the Medicare Part D Annual Election period, running from October 15 through December 7 of this year and at other times during the future.… Read More

Additional Guidance on New Prescription Drug Reporting Requirement

September 15, 2022September 14, 2022Ed MacConnell

As previously reported in 2021, Section 204 of the Consolidated Appropriations Act, 2021 (“CAA”) requires plan sponsors of group health plans to submit informationannually about prescription drugs and health care spending to Centers for Medicare and Medicaid Services (“CMS”) on behalf of the Departments of Health and Human Services(“HHS”), Labor (“DOL”), and the Treasury (collectively, the “Departments”). The first deadline is December 27, 2022. CMS recently updated guidance related to this reporting requirement that provides some helpful clarification. Click the link below to download this bulletin. As always please contact your Total benefit Solutions, Inc health insurance specialist at (215)355-2121 if you have any further questions or concerns.

New FAQ Addresses NSA and TiC Rules

September 14, 2022Ed MacConnell

he Departments of Labor, Health and Human Services and the Treasury (collectively, “the Departments”) issued FAQ Part 55, providing guidance as it relates to certain aspects of the No Surprises Act (“NSA”) and the Transparency in Coverage (“TiC”) final regulations. FAQ 55 includes 23 questions and answers. The guidance is lengthy and very detailed. Below you will find some of the key highlights of the guidance. Please download the bulletin below for details and contact your Total Benefit Solutions, Inc health insurance specialists at (215)355-2121 with any additional questions or concerns.

Further Guidance Issued on Contraceptive Coverage

September 12, 2022August 15, 2022Ed MacConnell

On July 28, 2022, the Departments of Labor, Health and Human Services and the Treasury (collectively, “the Departments”) issued FAQ Part to clarify protections for contraceptive coverage under the Affordable Care Act (the “ACA”). In January 2022, the Departments had issued guidance on the ACA Preventive Care Mandate, including contraception. The Departments issued FAQ Part 54: In response to reports that individuals continue to experience difficulty accessing contraceptive coverage without cost sharing; To clarify application of the contraceptive coverage requirements to fertility awareness-based methods and to emergency contraceptive; and To address federal preemption of state law. Employers sponsoring non-grandfathered group health plans should review the various preventive care requirements effective… Read More

IRS Announces 2023 ACA Affordability Indexed Amount

August 25, 2022August 8, 2022Ed MacConnell

The IRS recently announced in Revenue Procedure 2022-34 that the Affordable Care Act (“ACA”) affordability indexed amount under the Employer Shared Responsibility Payment (“ESRP”) requirements will be 9.12% for plan years that begin in 2023. This is a notable decrease from the 2022 percentage amount (9.61%) and below the original 9.5% threshold. Rev. Proc. 2022-34 establishes the indexed “required contribution percentage” used to determine whether an individual is eligible for “affordable” employer-sponsored health coverage under Section 36B (related to qualification for premium tax credits when buying ACA Marketplace coverage). However, the IRS explained in IRS Notice 2015-87 that a percentage change under Section 36B will correspond to a similar change… Read More

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