Patient Protection and the Affordable Care Act Overview
The Medical Trust's Compliance History
Healthcare reform began in earnest in March 2009. In one year, it moved from a proposal to passage by the Senate and the House of Representatives, and on March 23, 2010 the Affordable care Act (ACA) was signed into law by President Obama.
In 2009 with the passage of the Denominational Health Plan (DHP), the Medical Trust became the provider of medical benefits for the Episcopal Church. The Medical Trust knew its plans would be impacted by the ACA, and kept abreast of the legislation, which continues to evolve to this day.
Church Health Plans and the ACA
The ACA doesn't directly address church plans. So the Church Alliance, a coalition of 37 church benefit programs including the Church Pension Group (CPG), has representatives meeting with congressional and government leaders regarding how healthcare reform will apply to church plans. The Church Alliance wants to ensure that any legislation considers the interests and unique positions of health benefit plans operated by churches and religious institutions. We'll continue to keep you updated on these efforts.
How The Medical Trust Complies
The Medical Trust's plans are in compliance with all current provision of the ACA. In fact, the Medical Trust had instituted many of these provisions prior to healthcare reform, as they were in the best interests of those we serve.
- No-cost preventive care services. Plan members are provided 100% coverage (no cost-sharing) for preventive services or items for men, women, and children as outlined by the U.S. Preventative Services Task Force.
- No pre-existing condition limitations. Eligible members are not excluded from coverage on the basis of their individual health conditions.
- No retroactive rescission of coverage, except in case of fraud or misrepresentation and other limited circumstances.
- Coverage is not canceled on the basis of individual health status.
- Women's preventive health expansion. This provision requires that women's preventive health services are provided with no cost-sharing, and include a wide variety of services outlined in our Plan Handbooks.
- Coverage of adult children to age 26. The Medical Trust eligibility provisions prior to healthcare reform already included eligible dependents to age 30. We have maintained age 30 as the cut-off, and as required by healthcare reform, eliminated the provisions that eligible dependents age 30 or younger must live at home, be full-time students, be unmarried or have no dependents of their own.
- No annual or lifetime maximums. The Medical Trust health plans have no annual or lifetime maximums.
- Implementation of out-of-pocket maximums. Both medical/behavioral and pharmacy benefits have out-of-pocket maximums. These will run separately for most plans, however, in all instances when totaled together they will result in the plan's overall out-of-pocket maximum being at or below the ACA required levels.
- Summaries of benefits and coverage. The Medical Trust has always provided members with summaries of benefits and coverage, but they were redesigned to comply with the standard universal templates, which make it easy to compare plans.
- Form W-2 Reporting. Employers offering the Medical Trust health plans continue to be exempt from this provision for the 2015 reporting due in 2016. Employers offering health coverage through a source other than the Medical Trust may be required to provide the value of their employee's health coverage on each employee's Form W-2. Employers not providing healthcare coverage to their employees through the Medical Trust should consult with their payroll provider. Reporting for the 2016 plan year in 2017 is still to be determined.
Minimum Essential Coverage (MEC) statements. Beginning in 2016 for the 2015 plan year, the Medical Trust will issue Form 1095-B to participants by March 31, 2016* stating whether they have Minimum Essential Coverage (MEC). A copy of Form 1095-B will also be submitted to the Internal Revenue Service (IRS). We have begun the process of evaluating the data, tax reporting, and communication needs to ensure this reporting is completed in a timely manner. Certain large employers and small employers that sponsor a Health Reimbursement Arrangement (HRA) will also have tax reporting obligations that are outlined in more detail in the Next Steps section below.
- Patient Centered Outcomes Research Institute (PCORI) Fee. This fee will be assessed for a limited period of time (2012 - 2018) to help fund the new Patient Centered Outcomes Research Institute. The fees paid were:
- $1.00 per participant in 2012
- $2.00 per participant in 2013
- $2.08 per participant in 2014
- $2.17 per participant in 2015
The amount of the fee will be adjusted each year through 2018.
The Medical Trust pays this fee for health plans sponsored by the Medical Trust. If you offer other health plans to your employees (e.g., HRAs), you may be required to pay a separate fee for those plans.
- Transitional Reinsurance Program Fee. Sponsors of self-funded health plans, such as the Medical Trust, must pay, from plan assets, a $63 fee per covered individual in 2014, a $44 fee per covered individual in 2015, and $27 fee per covered individual in 2016. The revenue generated by the fee will be used to stabilize premiums in the new Health Insurance Marketplace during the years 2014 through 2016.
Opportunities Realized Through the ACA
The Medical Trust has also been able to maximize some opportunities for our member groups as a result of the ACA. These include:
Early Retiree Reinsurance Program
The Medical Trust applied for and received reimbursements from the Early Retiree Reinsurance Program (ERRP). These totaled over $560,000 for plan year 2010, and over $190,000 for plan year 2011. These reimbursements were used to lower 2012 premium increases. The government funding for this plan is now exhausted.
Small Employer Tax Credit
The Small Employer Health Care Tax Credit was created to encourage small employers to continue to offer healthcare coverage to their employees. The credit was implemented for the 2010 tax year, and is due to continue through the 2016 tax year. Beginning with the 2014 tax year, eligibility and certain other criteria and features of the program were changed. For full information, see Small Employer Health Care Tax Credit.
Please note that this update is provided to you for informational purposes only and should not be viewed as investment, tax, legal or other advice. Please consult your own professional advisors for further guidance.
Health benefits are offered through plans maintained by Church Pension Group Services Corporation (doing business as The Episcopal Church Medical Trust), 19 East 34th Street, New York, NY 10016.