Additional Guidance on New Prescription Drug Reporting Requirement

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.

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Inflation Reduction Act: Capping Medicare Part D Out-of-Pocket Spending and Other Part D Benefit Changes

Changes would lower beneficiary spending, reduce Medicare’s liability for high drug costs, and increase Part D plan and manufacturer liability for high drug costs. Beneficiaries: Eliminates 5% coinsurance for catastrophic coverage in 2024 Caps out-of-pocket drug spending at $2,000 beginning in 2025 Allows spreading out of out-of-pocket costs over the year Limits premium growth to no more than 6% per year for 2024-2030 Medicare: Lowers share of costs above the out-of-pocket spending cap (“reinsurance”) Part D Plans: Increases share of costs above the out-of-pocket spending cap Modifies share of costs below the out-of-pocket spending cap Drug Companies: Requires a price discount on brand-name drugs above the out-of-pocket spending cap Modifies… Read More

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What is a premium?

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

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Reminder: New Cost-Sharing Disclosure in 2023

Another compliance deadline is quickly approaching. For plan years that begin on or after January 1, 2023, group health plans must provide for advance disclosure of cost-sharing information to enrollees seeking health services, upon request and to the extent practicable. The format of the disclosure is through an internet-based self-service tool, telephone, or paper format (upon request). The tool allows the enrollee to compare the amount of cost-sharing that he or she would be responsible for with respect to a discrete covered item or service by billing code or descriptive term. The required information relates to geographic region and in-network and out-of-network providers and initially addresses 500 items and services.… Read More

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3 Types of Medigap Rating Structure

Attained-Aged: Premium based on current age when policy is issued. Premium goes up as you get older AND may go up due to a rate increase. All Medigap Freedom plans are Attained-Aged rated. Issued-Aged: Premium based on the age you are when you buy (are issued) the Medigap policy. Premium DOES NOT go up as you get older AND may go up due to a rate increase. Community: Same premium is charged to everyone who has the Medigap policy, regardless of age. Premium DOES NOT go up as you get older AND may go up due to a rate increase. Call your Total Benefit Solutions, Inc Medicare health insurance specialists… Read More

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

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

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New Jersey New Poster Requirements

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

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

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.

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What is an expected benefit Health Reimbursement Arrangement?

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

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

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

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

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.

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

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

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Blue KC: Members Can Soon Access Rx Savings Solutions and Find Care in One Place

In October, Rx Savings Solutions will integrate with the Find Care tool on MyBlueKC.com and the MyBlueKC mobile app. Rx Savings Solutions is a secure, online tool that helps eligible members find ways to save money on prescription drugs. Once integrated, the two tools will allow members to view medical and pharmacy in one place and better use both tools. The integration is one way we’re helping reduce the total cost of care for members, employers, and health plans. Eligible members can follow this path to Rx Savings Solutions: MyBlueKC.com Click Find Care in the left column Click Find Doctors, Specialists & Hospitals Click Medication Finder Have any questions regarding… Read More

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Part D Senior Savings Model: Will step therapy apply with insulin drugs?

Step therapy is when a Part D plan requires enrollees to first try certain drugs to treat a medical condition before the plan will cover another drug for that condition. The Model doesn’t change Part D sponsors’ formulary requirements. Enrollees can find out if the insulin or insulins they use have any additional step therapy requirements or limits by looking at the Part D plan’s formulary. Have any questions regarding this notice? Please contact your Total Benefit Solutions Medicare health insurance specialists at (215)355-2121.

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

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.

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

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

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Health Insurer Ordered to Stop Selling in Washington

Medova Healthcare, which sold illegal insurance plans through chambers of commerce, has agreed to stop selling in Washington, according to the Office of the Insurance Commissioner. The company also agreed to a $310,000 suspended fine, according to the OIC. It operated in 38 states including Washington and served 35,000 employees nationwide. Medova sold health insurance plans to almost 140 small businesses in the state, covering 1,487 employees, through chambers of commerce. One of them mentioned in the OIC investigation was the Lakewood Chamber of Commerce. The chamber did not respond to inquiries. The health plans were marketed to small businesses as traditional insurance plans, but they were self-funded Employment Retirement… Read More

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Prescription Drug Provisions in the Inflation Reduction Act

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

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Open Enrollment Tips!

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

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Understanding the Health Care Provisions in the Inflation Reduction Act

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

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The Employer Shared Responsibility Provision Estimator

The Taxpayer Advocate Service developed the Employer Shared Responsibility Provision (ESRP) Estimator to help employers understand how the provision works and learns how the provision may apply to them. The provision applies to applicable large employers – generally, that means employers that had an average of at least 50 full-time employees (including full-time equivalent employees-FTEs), during the preceding calendar year. If you are an employer, you can use the estimator to determine: The number of your full-time employees, including FTEs, Whether you might be an applicable large employers, and If you are an applicable large employer, an estimate of the maximum amount of the potential liability for the employer shared… Read More

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When is the Part D Senior Saving Model expected to end? How many years is the model?

Since CMS is testing the Part D Senior Savings Model to lower costs and improve health care quality, it has a set period for when it’s available. Part D plans participating in the Model first became available on January 1, 2021. The Model extends until December 31, 2025, but the plans participating in the Model may change each year. Please contact your Total Benefit Solutions Medicare health insurance specialists at (215)355-2121, if you have any questions or concerns.

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Medigap Open Enrollment Period

Most beneficiaries get ONE Medigap Open Enrollment Period. The Medigap Open Enrollment Period cannot be changed or repeated. Under 65 Medicare beneficiaries get another Medigap Open Enrollment Period when they turn 65. As always, please contact your Total Benefit Solutions, Inc health insurance specialists with any questions or concerns at (215)355-2121.

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Further Guidance Issued on Contraceptive Coverage

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

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What is a Medicare Coverage Gap?

Most plans with Medicare prescription drug coverage (Part D) have a coverage gap (called a “donut hole”). This means that after you and your drug plan have spent a certain amount of money for covered drugs, you have to pay all costs out-of-pocket for your prescriptions up to a yearly limit. Once you have spent up to the yearly limit, your coverage gap ends and your drug plan helps pay for covered drugs again. As always, please contact your Total Benefit Solutions Medicare health insurance specialists today at (215)355-2121.

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