Reminder: New Cost-Sharing Disclosure in 2023

Ed MacConnell

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

Ed 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

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New Jersey New Poster Requirements

Ed 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

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

Ed 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.

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What is an expected benefit Health Reimbursement Arrangement?

Ed 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

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

Ed 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

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

Ed 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.

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

Ed 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

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

Ed MacConnell

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?

Ed MacConnell

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?

Ed 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.

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

Ed 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

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Health Insurer Ordered to Stop Selling in Washington

Ed MacConnell

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

Ed 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

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Open Enrollment Tips!

Ed MacConnell

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

Ed 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

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What is an Out-of-Pocket Maximum/Limit?

Ed MacConnell

The most you have to pay for covered services in a plan year. After you spend this amount on deductibles, copayments, and coinsurance for in-network care and services, your health plan pays 100% of the costs covered benefits. The out-of-pocket limit doesn’t include: Your monthly premiums Anything you spend for services your plan doesn’t cover Out-of-network care and services Costs above the allowed amount for a service that a provider may charge The out-of-pocket limit for Marketplace plans varies, but can’t go over a set amount each year. For the 2022 plan year: The out-of-pocket limit for a Marketplace plan can’t be more than $8,700 for an individual and $17,400… Read More

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The Employer Shared Responsibility Provision Estimator

Ed MacConnell

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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Additional Guidance on New Prescription Drug Reporting Requirement

Ed 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.

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

Ed MacConnell

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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Further Guidance Issued on Contraceptive Coverage

Ed 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

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Guaranteed Issue Rights

Ed MacConnell

Guaranteed Issue (GI) rights are rights the beneficiary has in certain situations when insurance companies must offer certain Medigap policies. There are ONLY 7 situations where Guaranteed Issue Rights apply. Two of the most common are: Beneficiary is in a Medicare Advantage Plan, and the plan is leaving Medicare or stops giving care in their area, or the beneficiary moves out of the Medicare Advantage plan’s service area. Beneficiary has Original Medicare and an employer group health plan (including retiree or COBRA coverage) or union coverage that pays after Medicare pays and that plan is ending. Just like with the Medigap Open Enrollment Period, during a Guaranteed Issue: No eligibility… Read More

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What plans are part of the Part D Senior Savings Model?

Ed MacConnell

The Centers for Medicare & Medicaid Services (also known as CMS, the federal agency that approves Medicare plans) announced Medicare Advantage plans with prescription drug coverage (MA-PD) and Part D prescription drug plans (PDPs) that are participating in the Model for Calendar Year (CY) 2022 in September 2021. You can call 1-800-MEDICARE to ask questions about enrollment, eligibility, and the Model, or visit Medicare Plan Finder at https://www.medicare.gov/plan-compare/ to search for coverage in your area and compare Part D plan options with the lowest prices for your prescriptions. You can also find a list of participating plans on the Model website at https://innovation.cms.gov/media/document/pdss-2022-model-landscape-file. If you have any questions, please contact… Read More

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What is a health insurance deductible?

Ed MacConnell

The amount you pay for covered health care services before your insurance plan starts to pay. With a $2,000 deductible, for example, you pay the first $2,000 of covered services yourself. After you pay your deductible, you usually pay only a copayment or coinsurance for covered services. Your insurance company pays the rest. Many plans pay for certain services, like a checkup or disease management programs, before you’ve met your deductible. Check your plan details. All Marketplace health plans pay the full cost of certain preventive benefits even before you meet your deductible. Some plans have separate deductibles for certain services, like prescription drugs. Family plans often have both an… Read More

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Defined Contribution Plans

Ed MacConnell

The Issue As one of our long-time group insurance customers grew over the years, their workforce became more diverse and the management team found it difficult to accommodate each employee’s unique insurance needs. As much as the team wanted to provide the necessary coverage for the employees, they also required some control over the employee benefits budget. They came to us for advice. The Solution We proposed that this employer consider a defined contribution strategy. Defined contribution plans build benefit portfolios around a specific dollar amount, rather than around a specific plan or plans. In this way, the management team could select an amount that the company would contribute toward… Read More

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