Who says that the healthcare industry is boring?! 2018 has brought about many questions, changes, and updates. We’re going into four of the big ones that everyone should know about.
Read on to learn more!
1. Model Exchange Notice Expiration Date Extension
The Department of Labor (DOL) extended the expiration date on its Model Exchange Notice through May 31, 2020. The Model Notice is used to ensure compliance with the Exchange Notice requirement of the Affordable Care Act (ACA).
The expiration date of the Model Notice is included as an administrative function of the DOL and has nothing to do with how applicable the Notices are. The content of this Model Notice does not change substantively, so the expiration date does not affect an employer’s ability to use it.
It’s advised that employers provide new hires with an exchange notice. However, according to guidance from the DOL, there is no fine or penalty under the ACA for failing to provide the Notice.
2. IRS and DOL Guidance on AHPs
The Department of Labor (DOL) published a final rule in June 2018 that expands the ability of employers to join together to form association health plans (AHPs).
An AHP is covered under ERISA and is a type of group health plan sponsored by a group of employers. We go into deeper detail on the final rule, what AHPs are, and how they work in this blog post.
If you are a small employer that is considering joining an AHP, it is important to understand the compliance obligations associated with these sorts of plans. While it’s true that AHPs do avoid some Affordable Care Act reforms for the small group market, they are still subject to many other legal requirements and regulations.
3. Limits for HSAs and HDHPs Increase for 2019
In May 2018, the Internal Revenue Services (IRS) released Revenue Procedure 2018-30 to announce the new 2019 limits for health savings accounts (HSA) and high deductible health plans (HDHP). These limits detail the maximum HSA contribution, the minimum deductible amount for HDHPs, and the maximum out-of-pocket expense limit for HDHPs. These limits vary based on whether an individual elects self-only or family coverage under an HDHP.
The HSA contribution limit increase will go into effect on January 1, 2019, and the HDHP limits will increase for plan years beginning on or after January 1, 2019.
Learn more about these limits and the specific costs and requirements here.
4. Final Rule Expands Short-term, Limited-duration Insurance
Short-term, limited-duration insurance is designed to fill any temporary gaps in coverage when an individual is transitioning from one plan or coverage to another. Short-term, limited duration insurance is exempt from the definition of individual health coverage and, therefore, not subject to the market reform requirements of the Affordable Care Act.
Originally, in 2016, the definition of short-term, limited-duration insurance was revised so that it would be excluded from the definition of individual health insurance coverage. This led to concerns that limiting the length of short-term, limited-duration insurance would reduce consumer options for affordable coverage. So in 2018, the 2018 final regulations lengthened the maximum period of short-term, limited-duration insurance, with the hope of providing more consumer choices for affordable healthcare.
As it stands, short-term, limited-duration insurance may offer a maximum coverage period of less than 12 months after the original effective date of the contract. This approach takes into account any extensions that may be elected by the policyholder without the issuer’s consent provided that the duration is less than 3 years in total.
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