Thank you to the following
expert panelists for participating in thefirst of
a series of panel
discussions, presented by MassAHU, on the
Nuts
n'Bolts of Health
Care Reform Implementation:
|
Jeff Rich, Northeast
Business Trust
|
|
Henry Marcy, Division
of Unemployment Assistance, Fair Share Contribution Management
Analyst
|
|
Richard Szczebak,
Attorney, Commonwealth Connector
|
|
Elba Mendez, Commonwealth
Choice Implementation Manager
|
| Ross Weiler,
Director of Strategic Accounts, Commonwealth Connector |
This informational,
interactive presentation, MA approved for 2 CE's, reviewed and updated
brokers on specific regulations on health care reform, the changes
made that affect Fair Share Contribution, HIRD forms and the Section
125 Cafeteria Plans and provided guidance for employers navigating
and implementing Commonwealth
Choice Voluntary Plans.
Please see the following guidelines in this August Administrative Update released by the DUA, DHCFP and the Connector with this new policy information that will impact FSC/HIRD, the
S125 Filing and that the Enrollment Deadline is fast approaching:
Fair Share/HIRD: DUA announced yesterday that
due to ER resistance (and some push back by all of us), payroll hours will
not need to be collected by ERs in order to pass the Primary Test. This
is great news. Instead of collecting payroll hours, ERs will
be asked to calculate the average number of enrolled employees in their
group health insurance programs as of the last day of the
following quarters: Q4’06’ Q1’07; Q2’07; Q3’07. Obviously,
these quarters coincide with the reporting period of 10/1/06 to 9/30/07
(which is not changing). A similar calculation needs to record
the average number of total full-time EEs as of the last day for the
same calendar quarters to determine the percentage of enrolled to total
FT EEs. Also an FTE will be defined in the following way:
-
Those EEs who work the majority of his/her time
(50%+) during the period of each respective calendar quarter;
-
Eligibility for health insurance based on the lesser of
the following: weekly payroll hours needed to be eligible for employer-sponsored
health insurance or 35 hours of employment per week (i.e.
so if an EE works 25 hours/week and eligibility for health
insurance at a firm is based on working 20 hours a week or more,
this EE would meet this part of the definition)
Some key elements have not changed:
reporting period; ERs must complete both Primary and Secondary tests;
if the ER has a waiting period of longer than 90 days, they will fail
the Secondary Test; information is due on 11/15/07 and must be completed
on-line. Just to keep things simple, the definition of FTE for
the Secondary Test is different than that for the Primary Test. The
definition of FTE for the Secondary is the definition of eligibility
as agreed to by the ER and the health plan/carrier.
Section 125 Plan Policy: Two
changes here. First, ERs will not have to file
their Sec 125 plan documents with the Connector unless requested to
by the Connector. If requested, the filing is due within 7 business
days of the Connector’s request. Finally, any Sec 125 plan maintained
by an ER that is not available to an EEs employed at a Mass location
is not subject to the filing requirement. Secondly,
students who are employed as PT EEs at their college or university
and who are required to participate in a student health insurance
program or in a comparable health plan may be excluded as a class
from participation in an ER’s Sec 125 plan.
Enrollment Deadline: As
a reminder, the last day for enrollments by PT EEs in the Connector’s
Voluntary Plan is October 10, 2007 in order to be assured of coverage
by December 1, 2007 and to beat the penalty. As this deadline
is less than two months away, make sure that your clients for
which offering the Connector for PT or W2 contract EEs is appropriate
have their Sec 125 plans amended or a new one created, have their
accounts set-up, and define an enrollment period for these workers
to buy insurance pre-tax. Any enrollments for the Voluntary
Plan received after this date will become effective on January 1,
2008. If you need help or on-site assistance for your clients,
let me know and you’ll get the help you need.
New Web Site Functionality: As
many of you know, our web site has been significantly enhanced in
the past month to make enrollment easier for you and your clients
and their PT EEs. We have roughly 3,000 groups enrolled for
the Voluntary Plan. Next week, the Broker section of the web
will be enhanced to allow you to enroll your clients directly from
this part of the site.
