What You Should Know:
The Centers for Medicare and Medicaid Services (CMS) and the U.S. Department of Health and Human Services (HHS), require that employers who participate in Employer Sponsored health insurance programs provide information about the size of their workforce.
To comply with regulations and provide accurate information, employers need to complete a questionnaire that will be provided by their respective insurance carrier:
Why is this Data Collection Required?
About CMS Data Collection
Health insurance carriers must collect and report specific employee counts for each participating employer to CMS to satisfy Section 111 of the Medicare, Medicaid and State Children’s Health Insurance Plan Extension Act of 2007 (MMSEA).
The data is used by CMS to determine if Medicare is the primary or secondary payer for your employees and their dependents who are eligible for Medicare. This information is required even if you have no Medicare eligible employees or dependents.
Employers who do not submit this information will automatically have their group size reported to CMS as greater than 20 employees, which will limit or change the plan availability for individuals who are otherwise eligible for a Medicare plan.
About MLR Classification
The ACA requires insurance carriers that offer fully insured health plans to calculate and report their medical loss ratio (MLR) annually to HHS. Insurance Carriers must collect detailed information regarding the total number of employees in a company so that they can determine whether the business is classified as small or large under MLR regulations. This information will also be used by the health insurance carriers to determine whether an employer group is entitled to a premium rebate, if applicable.
Employers who do not submit this information will have the number of employees reported to HHS based off of an insurance carrier's billed employee count. This may not be the same as the total number of employees and may affect the employer's MLR classification, which is used to determine whether your group is eligible for any applicable carrier premium rebate.
On June 22, 2017, the U.S. Senate introduced a bill to repeal and replace the ACA. The bill, called the Better Care Reconciliation Act (BCRA), is the Senate’s response to the American Health Care Act (AHCA), which the House passed back in May. In introducing the BCRA, Senate Majority Leader Mitch McConnell said he anticipated a vote on the BCRA before Congress’s week-long Fourth of July recess. It now appears that the vote won't happen until after the break. Because the bill is a reconciliation bill, it requires only a majority of senators to approve in order to pass the Senate — although it’s unclear whether there’s enough Republican support in the Senate to achieve a majority.
The BCRA makes some of the same ACA changes as does the AHCA. Those include repealing the ACA’s individual and employer mandate penalties, health FSA contribution limits and health insurance tax. It also includes several changes to HSAs: amending HSA contribution limits to align with the HSA-qualifying HDHP out-of-pocket maximums, allowing reimbursements from an HSA that are incurred after HDHP enrollment but prior to the HSA’s establishment, and allowing catch-up contributions from both spouses to the same HSA. Similar to the AHCA, the BCRA allows reimbursements from HSAs, FSAs and HRAs for over-the-counter (non-prescription) medications and delays the so-called “Cadillac tax” until 2026. Those similarities to the AHCA would likely be viewed as welcome by employers, since they reduce administrative requirements on reimbursement accounts and either relax or completely do away with some employer compliance obligations (like the need to track hours, run measurement periods and offer affordable coverage to full time employees under the employer mandate).
In March, we posted Connecticare's decision to change the age for Preventive (No cost) Mammogram Screenings.
ConnectiCare has since reversed this decision.
Preventive mammogram screenings for women age 40 and over will continue to be exempt from all cost-shares.
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