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Are you ready for Open Enrollment Season??

Author: Jan Fernandez    Posted: August 25, 2016

With over 69% of all employer sponsored health plans renewing January 1, 2017 it’s time to get ready for your employees Open Enrollment period; but are you going to be ready?

2017 holds new legal changes affecting the design and administration of your plans. You should review your plan documents to confirm that they include the required changes. Do you have a Summary Plan Description “SPD” or summary of material modifications “SMM”? This is different than the blue and white SBC that you’ve been passing out for the past few years. Speaking of SBC’s, there are more fun filled documents that need to be distributed: annual CHIP notice, Medicare Part D creditable coverage notice, Notice of grandfathered status (if applicable), annual notice regarding coverage requirements for mastectomy related benefits (WHCRA notice), Michelle’s Law Notice, and the list goes on.

Other things to be aware of for 2017 are HDHP and HSA limits for 2017; they went up. According to our friends at SHRM limits for 2017 are $3,400 self only and $6,750 for a family enrolled in an HDHP, catch up for those over age 55 are still $1,000. Minimum deductibles are going to $1,300 for self only and $2,600 for families. One nice thing to note is that there are now certain maintenance drugs that are not subject to deductibles; you should check with your consultant for your respective carrier’s list. Out of pocket maximums have not gone up – thank goodness – they are still $6,550 for self and $13,100 for a family.

Wellness Programs
If your wellness program includes a health risk assessment (HRA) or medical examinations or covers spouses, you should consider your compliance requirements under new rules issued by the Equal Employment Opportunity Commission (EEOC) under the Americans with Disabilities Act (ADA) and the Genetic Information Nondiscrimination Act (GINA). These new rules are effective for plan years beginning on or after Jan. 1, 2017. For example, under these rules:

    Incentive Limits – Incentives that are tied to the wellness program cannot exceed 30 percent of the total cost for self-only coverage. If spouses participate in the wellness program, their maximum incentive also cannot exceed 30 percent of the total cost of self-only coverage.

    Confidentiality – Information from the wellness program may be disclosed to employers only in aggregate terms.

    Employee Notice – Employers must give participating employees a notice that tells them what information will be collected as part of the wellness program, with whom it will be shared and for what purpose, the limits on disclosure and the way information will be kept confidential. The EEOC has provided a sample notice to help employers comply with this ADA requirement.

More on SBCs
In connection with your plan’s 2017 open enrollment period, the SBC should be included with the plan’s application materials. If plan coverage automatically renews for current participants, the SBC must generally be provided no later than 30 days before the beginning of the new plan year.

The new SBC template should be used for health plans with open enrollment periods or plan years beginning on or after April 1, 2017.

For self-funded plans, the plan administrator is responsible for providing the SBC. For insured plans, both the plan and the issuer are obligated to provide the SBC, although this obligation is satisfied for both parties if either one provides the SBC. Thus, if you have an insured plan, you should confirm that your health insurance issuer will assume responsibility for providing the SBCs. Please contact your representative at Rapport Benefits Group for assistance.

Don’t forget COBRA Notices
For employers with more than 20 employees over the past six months, don’t forget about Cobra open enrollment. Does your Cobra administrator really send out the Open Enrollment Packets to all Cobra eligible participants? And, if you are one of those employers who have carriers charging age banded rates but you want to charge your employees an average or composite rate, remember that if your older cobra participants elect Cobra, you cannot charge them more for their Cobra premium than what your composite rate was.

If you would like to sit down and talk about ALL the compliance requirements coming up, we are happy to go over a check list with you.

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