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HRA's and Indemnity Plans Guidance
- Thread starter Yagents
- Start date
- 8,448
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Is anyone really surprised by HHS explanation?
Did any of us think that the HRA could act as QHP?
The big question for me, does the HRA benefit count towards the federal poverty level?
Did any of us think that the HRA could act as QHP?
The big question for me, does the HRA benefit count towards the federal poverty level?
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- #15
The point of the law, was to eliminate bad plans that cause bankruptcy. I heard Obama say that 100 times. I hope LB plans are eliminated as primary insurance vehicle, and used as supplemental to a MM policy as initially intended.
Feds: Some "indemnity plans" come under PPACA | LifeHealthPro
Feds: Some "indemnity plans" come under PPACA | LifeHealthPro
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It's interesting that you mention that. When I look at the plan designs, some of those that would qualify for precious metal designation are less benefit rich that what I currently sell under an HDHP banner - and are more expensive. Some benefits will go up as of 2014, but the deductible/coinsurance situation is maddening vs. a 100% HDHP.
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- #18
Metal plans have OOP's that are tied to HSA maximums of $6250. So, if you compare a $6250 HDHP then 100% coverage, to a metal plan that has lower deductibles and copays, then you arrive at the metal plans costing more for these reasons. But both have the same OOP.
For what it’s worth, here is my take.
1. Delay, no problem or issue.
2. HRA integrated—HHS has decided that a large group cannot use a stand-alone HRA, funded with ER dollars, for the employee to purchase individual coverage. A HRA used with a MM type (PPO, HMO, etc) plan is still allowed because even though the HRA is limited it is used with another plan which if designed correctly will satisfy the rules.
3. Indemnity plans—may be confusing because they are addressing the fixed indemnity plans ($100 per day in hospital) here, not a traditional indemnity MM plans.
4. 60%--refers to Actuarial Value, not premium contributions.
By the way, for anyone who likes this type of minutia, the % refers not to the actual amount the plan paid out. It refers to what the plan would have paid (charges) out for a standard population. If you look at the 4 metal levels of coverage available, I bet the actual payouts will be different than expected. We should expect to see healthier people enroll in 60 and 70%’s plans and the sicker to enroll in the 80 and 90% plans. Because of this, the actual enrolled population will not be standard, thus skewing the charges. The 60 and 70% plans will pay out less while the 80 and 90’s will pay out more.
1. Delay, no problem or issue.
2. HRA integrated—HHS has decided that a large group cannot use a stand-alone HRA, funded with ER dollars, for the employee to purchase individual coverage. A HRA used with a MM type (PPO, HMO, etc) plan is still allowed because even though the HRA is limited it is used with another plan which if designed correctly will satisfy the rules.
3. Indemnity plans—may be confusing because they are addressing the fixed indemnity plans ($100 per day in hospital) here, not a traditional indemnity MM plans.
4. 60%--refers to Actuarial Value, not premium contributions.
By the way, for anyone who likes this type of minutia, the % refers not to the actual amount the plan paid out. It refers to what the plan would have paid (charges) out for a standard population. If you look at the 4 metal levels of coverage available, I bet the actual payouts will be different than expected. We should expect to see healthier people enroll in 60 and 70%’s plans and the sicker to enroll in the 80 and 90% plans. Because of this, the actual enrolled population will not be standard, thus skewing the charges. The 60 and 70% plans will pay out less while the 80 and 90’s will pay out more.
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Here is an excerpt from the Life/Health Professional article that Stuy119 linked to in his post (above).
""The indemnity insurance also "must pay a fixed dollar amount per day (or per other period) of hospitalization or illness (for example, $100 per day) regardless of the amount of expenses incurred," officials said.
Some health insurers or distributors are marketing "indemnity coverage" that, for example, pays $50 for a doctor's visit or various rates for various surgical procedures.
To qualify as a fixed an indemnity policy, a policy must pay "a fixed dollar amount per day (or per other period)," officials said.
"When a policy pays on a per-service basis as opposed to on a per-period basis, it is in practice a form of health coverage instead of an income replacement policy," officials said. "Accordingly, it does not meet the conditions for excepted benefits.""
In a nutshell, is this new guidance from the government stating that Limited Benefit Indemnity plans will not be allowed to pay $xxxx.xx dollars per medical need? For example... $20,000 for surgery, or $500 per outpatient test, etc..? If so, this is HUGE, because most of them have these "per type of service" reimbursement provisions. Is this how my esteemed colleagues interpret this, and is it part of an actual HHS rule, or something that HHS is merely thinking about? Knowledge-based feedback....PLEASE. T.I.A.
-Allen
""The indemnity insurance also "must pay a fixed dollar amount per day (or per other period) of hospitalization or illness (for example, $100 per day) regardless of the amount of expenses incurred," officials said.
Some health insurers or distributors are marketing "indemnity coverage" that, for example, pays $50 for a doctor's visit or various rates for various surgical procedures.
To qualify as a fixed an indemnity policy, a policy must pay "a fixed dollar amount per day (or per other period)," officials said.
"When a policy pays on a per-service basis as opposed to on a per-period basis, it is in practice a form of health coverage instead of an income replacement policy," officials said. "Accordingly, it does not meet the conditions for excepted benefits.""
In a nutshell, is this new guidance from the government stating that Limited Benefit Indemnity plans will not be allowed to pay $xxxx.xx dollars per medical need? For example... $20,000 for surgery, or $500 per outpatient test, etc..? If so, this is HUGE, because most of them have these "per type of service" reimbursement provisions. Is this how my esteemed colleagues interpret this, and is it part of an actual HHS rule, or something that HHS is merely thinking about? Knowledge-based feedback....PLEASE. T.I.A.
-Allen
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