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Click here for the Lafayette Square News Archive

CURRENT ISSUE:

November 2003:  Health Insurance Industry News

     Thank you to all who attended our recent HR Seminar and helped to make it a success!  By your feedback the most popular section was the Workers’ Compensation.  Test your knowledge by reading the following article taken from the California Chamber of Commerce web site.

Ten Most Common Workers’ Compensation Misconceptions

1. Employees should be treated by their own physician for all work-related illness or injury.
You have the right to select the doctor who provides care for your employee’s work-related injuries or illnesses for the first 30 days following an incident, unless the employee has predesignated his/her personal physician. 

2. Time away from work for work-related illness or injury is not included in other protected leaves of absence.
Employers subject to FMLA/CFRA should advise eligible employees that workers’ compensation leave runs concurrently with leave under FMLA/CFRA for up to 12 weeks and give them applicable family medical leave notices.

3. If I offer an injured employee temporary modified duty, I must pay his/her regular rate of pay.
An offer of temporary modified duty to an employee who is receiving temporary disability benefits does not have to be at his/her regular salary.  The pay rate can be appropriate for the modified job and the employee can receive partial temporary disability pay from workers’ compensation.

4. I must continue my employee’s health benefits for the entire duration of workers’ compensation leave.
Employers with health plans subject to ERISA do not have to continue health benefits for the duration of an employee’s workers’ compensation leave.  Benefits must be continued for as long as you would provide them for employees on non-occupational medical leaves.  Thereafter, COBRA rights must be offered.

5. Workers’ compensation insurance only covers injuries occurring on the company’s premises.
Injuries that occur outside the workplace, even in an employee’s home, may be covered by workers’ compensation, provided they arise out of employment and occur in the course of employment.  This may include injuries that occur during commuting to and from work, if you control the employee’s route of travel or the employee is allowed to engage in work activities during the commute, such as cell phone calls.

6. Stress in an employee’s personal life is a major factor in workers’ compensation stress claims.
In order to receive workers’ compensation for stress, the employee must show that work accounts for more than 50% of all sources of stress.  Thus, evidence that the majority of stress factors can be attributed to non-work circumstances is an effective defense against stress claims.

7. A new employee who is unable to cope with the pressures of his/her job is a prime candidate for a successful workers’ compensation stress claim.
An individual who has been employed by you for less than six months will not be compensated for work-related stress, unless the stress results from a sudden and extraordinary employment condition.  Also, lawful, non-discriminatory, good faith personnel actions (such as discipline and terminations) are not grounds for stress claims.  Early action should therefore be taken when a new employee is identified as unable to cope with a job.

8. First aid cases need not be reported to my workers’ compensation carrier.
If an injured worker requires only first aid treatments and suffers no time lost from work beyond the date of the illness or injury, you may pay the doctor for the services direct, and avoid payment by your workers’ compensation carrier.  The Doctor’s First Report must still be filed.

9. I can refuse continued employment to an employee unless and until he/she fully recovers from a work-related injury.
An employee who is disabled as a result of work-related illness or injury will likely be considered disabled under state and/or federal law.  Employers must comply with disability discrimination laws and provide reasonable accommodation to such injured workers who can perform essential job functions.  Failure to do so may result in a claim under both workers’ compensation law and disability discrimination law.  However, you are not required to create a position or displace another employee.

10. A case of serious injury or death from a work-related incident need not be reported to Cal/OSHA until all the details have been identified.
You must report any work-related serious injury or death to Cal/OSHA within 8 hours after you know of the incident.  Failure to properly report can result in heavy fines and criminal prosecution.


In our last health insurance issue we told you about the recently passed SB 2, also known as, “Pay or Play”.  In summary, this bill would mandate minimum levels of health insurance, as well as set contribution levels for companies with 50 or more employees.  Those who do not meet the minimum standards would have to pay into a state fund which would be used to provide health coverage.

SB 2 - Pay or Play:  What Happens Now?
The Managed Risk Medical Insurance Board (MRMIB) is planning for SB 2 implementation, but opponents of the legislation may challenge it through one or more routes:

  • A state lawsuit that claims the "fee" is actually a tax that did not receive the required two-thirds majority vote in the legislature.
  • A federal lawsuit that claims the law violates the Employee Retirement Income Security Act of 1974 (ERISA), a federal law pre-empting states from regulating employer benefit plans.
    A referendum to repeal SB2 may be presented to the California voters. The California Chamber of Commerce has filed the required paperwork and would need about 375,000 signatures in order to place the measure on the ballot.  (Lafayette Square has already received a petition from the Chamber).

For more information on the bill and the challenges it faces see the links below.  All information is provided through the California HealthCare Foundation (CHCF) website. (http://www.chcf.org)

The Legislation and Related Information
See the final text and legislative analyses of Senate Bill 2.
Read a fact sheet on Hawaii's Prepaid HealthCare Act, the only state employer-mandate law in effect.   (This law was passed before ERISA and was granted an exemption from ERISA.)

Legal Issues and Challenges
A CHCF fact sheet discusses the law's potential conflict with ERISA. See ERISA Implications for SB 2.
The National Academy for State Health Policy published Revisiting Pay or Play: How States Could Expand Employer-Based Coverage Within ERISA Constraints.
The California Chamber of Commerce is seeking to overturn SB2 by referendum. Read information on the Chamber's plan and its opposition to SB2.


Do your employees know how much your company spends on benefits?  It is a good practice to provide employees with a summary of their total compensation including benefits.  (Don’t forget to include workers’ comp!)  Below is a summary of the averages statewide and in private industry.  For a further breakdown by company size and industry follow the link to the report.  

Benefits Were 28.3% of Total Compensation in June 2003, BLS Finds

Statewide. Employer-provided benefits costs for civilian workers in private industry and state and local governments in June 2003 averaged $6.84 per hour worked, accounting for 28.3% of total compensation costs, which averaged $24.19 per hour worked.  These are among the findings of the most recent Employer Cost for Employee Compensation report, produced quarterly by the Bureau of Labor Statistics (BLS).

Legally required benefits averaged $1.93 per hour or 8% of total compensation in June 2003, representing the largest nonwage employer cost.  Employer costs for paid leave benefits averaged $1.63 (6.7%), insurance benefits averaged $1.81 (7.5%), and retirement and savings benefits averaged 86 cents (3.6%) per hour worked.

Private Industry.  According to the BLS, private industry benefits costs averaged $6.30 per hour, accounting for 27.9% of total compensation costs, which averaged $22.61 per hour worked.  Private industry employer costs for paid leave averaged $1.46 per hour worked (6.5%), insurance benefits averaged $1.57 (6.9%), retirement and savings benefits averaged 67 cents (3%), and legally required benefits averaged $1.93 (8.4%) per hour worked.  The remaining costs were supplemental pay (64 cents or 3%), and severance and supplemental unemployment (3 cents or .1%).  Of the total insurance benefits, health insurance costs rose from $1.31 per hour worked and 6% of total compensation in June 2002, to $1.45 per hour and 6.4% in June 2003.

For more information, visit http://www.bls.gov/ncs/ect/home.htm.


ER Use Rise Attributed to Insured

People with insurance are increasingly using emergency rooms, even for non-urgent care, a study found – perplexing experts who thought the uninsured were the chief reason for ER overcrowding. Emergency room visits jumped to an average of 107.7 million a year in 2001 and 2000, up 16.3 percent from 1996 and 1997.Most of the increase came from insured patients, according to the Center for Studying Health System Change, a Washington think tank.

Privately insured patients’ use of the emergency room rose 24.3 percent to 43.3 million visits over that six-year period.  People covered by Medicare visited the ER 16 million times, a 10 percent increase. Visits by uninsured patients rose 10.3 percent to 18 million, while those by patients covered by Medicaid, the government program for the poor, were flat at 18.4 million. Only 46 percent of the ER visits by privately insured patients were considered either emergent – requiring care within 15 minutes of arrival – or urgent – requiring care within an hour of arrival.

“The results were surprising,” said Peter Cunningham, a senior health researcher at the Center for Studying Health System Change, who conducted the study using data from the Centers for Disease Control and Prevention as well as his organization’s own information.  “Uninsured people clearly are not a major factor in increased crowding at most hospital emergency departments, but uninsured people’s growing reliance on emergency care indicates decreased access to other sources of care.”

Some experts speculate that more patients are turning to the ER because doctor’s offices do not accommodate people’s working schedules.  Emergency rooms are open 24 hours a day and no appointments are necessary.  The study cited other research showing that patients are having difficulty making appointments with their doctors, and having to wait longer for appointments.  Some doctors are closing their practices to new patients.  And some people may go to the emergency room believing they have a true medical emergency, even though it turns out to be a minor problem.

“Sometimes people think they are having a heart attack, and it is only bad indigestion,” said Carmela Coyle, senior vice president for policy at the American Hospital Association.

Observers say the trend will only add to rising health care costs because treating someone in a hospital is more expensive than tending to them in a doctor’s office.  Dr. Joseph Guarisco, chairman of emergency medicine at the Ochsner Clinic Foundation in New Orleans, said his hospital has been seeing more insured patients in the ER for the past five years.  He believes a big reason is convenience.  Visiting the emergency room may not be prohibitively expensive for an insured patient – a copayment of $50 to $100 for a visit, rather than $10 to $20 for an office visit.

But a patient can see a doctor, have some tests and consult with the doctor again when the results come in all in one visit, instead of three separate appointments.  That option is especially appealing for those who do not want to take time off from work to see a doctor, Guarisco said.


Lafayette Square News Archive

September 2003 - Insurance Industry News

July 2003 - Insurance Industry News

Relief from Filing Form 5500

Health Costs Still Soaring

California Conforms to EGTRRA

More Employers Offering Long Term Care

Should You Take a Reduced Early Social Security Benefit?

Health Insurance Increases 18% CPI Increases 2.8%...WHY?

More Health Care Costs Increase RX Costs Going Higher– Why?

The HMO Chaos

Late Fees on Premium Payments Good News from Sutter and Blue Shield

Provider Update Low

New 401k Regulations & Limits

Happenings

Have You Shopped Online?

Blue Shield of CA Revises Small Group Plans

What Happened To My Medical Carriers Network of Doctors?

Domestic Partner Benefits: Overview

Getting Lab Bills Paid  

September 2003 - Health Insurance Industry News

IRS Announces Health FSA Reimbursement of Over-the-Counter Medications

On September 3, 2003 the IRS announced a new ruling that allows consumers that have Health Flexible Spending Accounts (FSAs) through their employers to use their FSA to purchase over-the-counter (OTC) medications effective immediately.  Until now, the only medications that were eligible for reimbursement through a FSA were drugs that required a prescription.  The ruling says that non-medically-necessary dietary supplements are not reimbursable.  For example, OTC medications such as antacids, allergy medicines, pain relievers and cold medicines will be reimbursable, while vitamins will not.

What does this mean for your FSA?  You should check with your plan administrator regarding your plan’s language on reimbursable expenses.  If you plan includes all reimbursable expenses as stated in I.R.C. Section 213, then it will automatically include this change.  If your plan simply lists the reimbursable expenses you will need to amend it if you wish to include OTC medications.  Regardless, participants can only change their annual FSA contribution amount at the beginning of the plan year.

It is believed that this ruling could significantly increase the participation in FSAs which are currently used by about 18% of the nation’s employees.  It should be noted that the biggest barrier to participation in FSAs is rollovers.  Currently, any unused portions of the funds set aside by a participant during a plan year are forfeited.  There are several bills under consideration in Congress that would allow FSA funds to be rolled over.

Department of Labor Announces Compliance Assistance Guide For Qualified Medical Child Support Orders

The U.S. Department of Labor's Employee Benefits Security Administration (EBSA) announced a new compliance assistance guide to help employers, plan sponsors, service providers and state officials understand the federal health benefits law regarding qualified medical child support orders.

Assistant Secretary of Labor Ann L. Combs said, "By developing this new publication as part of our continuing commitment to assist plan officials comply with the law, we will ultimately assist thousands of children secure health insurance coverage when their parents divorce or when mandated by state authorities."

 

The publication, which also will assist state child support enforcement agencies, explains the provisions of the Employee Retirement Income Security Act (ERISA) that require employer-sponsored group health plans to extend health care coverage to children of a employees who are divorced, separated or never married when ordered to do so by state authorities.

A state court or agency may require an ERISA-covered health plan to provide benefits coverage to children by issuing a medical child support order. A state child support enforcement agency may also obtain group health coverage for a child by issuing a qualified National Medical Support Notice.

Read the Compliance Guide for Qualified Medical Child Support Orders http://www.dol.gov/ebsa/publications/qmcso.html

 


SHRM Survey on Changes since 9/11

The Society for Human Resource Management conducted a survey during the week of September 2 – September 9, 2003, regarding the changes organizations have made since September 11, 2001.

Human resource professionals were asked, “In your opinion, what lasting changes, if any, have taken place in the workplace as a result of the September 11 terrorist attacks?”

64 percent

Organizations have put higher security provisions in place

48 percent

Higher expectations of employers for security

34 percent

Employees do not consider travel as glamorous

31 percent

Greater screening of employees for hire

27 percent

More training in crisis management

26 percent

Business travel has been curtailed

24 percent

Employees are reluctant to travel for business

22 percent

Workers have been more wary of their work environment

16 percent

Higher stress levels in the workplace

15 percent

HR is relied upon more for its expertise and input

13 percent

Employees are more caring towards one another

12 percent

Greater use of Employee Assistance Program (EAP)

10 percent

Business events have been cancelled

10 percent

No lasting change

6 percent

Other

For additional information on SHRM visit www.shrm.org 

JULY 2003

The Department of Labor announced the creation of a new online resource for employees.   You may want to include this information in the health benefits area of your hiring and exit packets.  The DOL media release below can be found at http://www.dol.gov/ebsa/newsroom/pr072103.html.

Release Date: 07/21/2003
Release Number: 03-391
Contact Name: Gloria Della

Phone Number: 202.693.8664

 

New Labor Department Web Site Can Help Millions Find Valuable Information On Health Benefits

Washington, DC - The U.S. Department of Labor's Employee Benefits Security Administration (EBSA) today announced the launch of a new interactive Web site that will serve as a resource to help employees and their families make informed decisions about their health benefits when facing life and work changes.

Assistant Secretary of Labor Ann L. Combs called the Web site, "an outstanding resource for the 131 million Americans and their families who rely on coverage from private-sector group health plans. It will be especially helpful when unanticipated events happen."

The Web site gives consumers information about:

§                     Health coverage under private plans and federal and state programs

§                     Definitions of key terms

§                     Links to other resources, including public health plans and state insurance offices nationwide.

The new Web site, which can be found at elaws Health Benefits Advisor, (http://www.dol.gov/elaws/ebsa/health/) asks employees questions, guiding them through easy-to-use helpful tools and facts about health benefits. Visitors to the site will learn the specific requirements and rights under laws like the Consolidated Omnibus Budget Reconciliation Act (COBRA) and the Health Insurance Portability and Accountability Act (HIPAA). More importantly, the Web site allows the public to obtain information about their rights and responsibilities under a group health plan upon the occurrence of specific life and work changes -- including marriage, childbirth, death, divorce, job loss, new job, or retirement.

EBSA is an agency within the Labor Department that oversees nearly 2.6 million health benefit plans nationwide. As part of its ongoing Health Benefits Education Campaign, the agency conducts education and outreach about health benefit issues in order to explain the rights and responsibilities associated with coverage by a group health plan. Other free publications under the campaign are available on EBSA's Web site or by calling toll-free 1.866.444.EBSA (3272).

This Employment Law Advisor is one of a series of elaws advisors (Employment Laws Assistance for Workers and Small Businesses), which are interactive e-tools that help individuals understand federal employment laws, such as the Fair Labor Standards Act (FLSA), the Family Medical Leave Act (FMLA) and the Uniformed Services Employment and Reemployment Rights Act (USERRA).

U.S. Department of Labor news releases are accessible on the Internet. The information in this news release will be made available in alternate format upon request (large print, Braille, audio tape or disc) from the Central Office for Assistive Services and Technology. Please specify which news release when placing your request. Call 202.693.7773 or TTY 202.693.7755.


 

The Department of Labor has proposed regulatory changes to COBRA.  The intent is to further clarify the notice requirements and ease the administrative burden.   Of course, the impact of these changes is unknown and industry response has been varied.  Once the proposed regulations are finalized we will update the COBRA section of our Employee Benefits Resource Guide and distribute the updated materials.   For now, we wish for you to be aware of the possible changes.

 

The following can be found at www.dol.gov/ebsa under Publications and Reports.

U.S. Department of Labor

Employee Benefits Security Administration (EBSA)

May 2003 Fact Sheet

Proposed Regulations on COBRA Notices

General COBRA Notice:

  • Under the proposed regulations, the general notice would cover the basic information on COBRA that employees and their families need to know to protect their rights before a qualifying event occurs.
  • The notice would be furnished to qualified individuals within 90 days after coverage begins.
  • Plans could satisfy this notice requirement by including the required information in the summary plan description (SPD) and furnishing the document within the 90-day time limit.
  • The proposal also includes a revised model general notice to make it easier for plan administrators to comply with the notice requirements.

Employer Notice of Qualifying Event:

  • Employers must notify plan administrators of certain types of qualifying events, such as loss of job, reduced working hours, death of the employee, and enrollment of an employee in Medicare.
  • The proposal clarifies the required timing and content of the notice of qualifying event.

Employee/Family Member Notice of Qualifying Event:

  • Employees or their family members must notify plan administrators of other types of qualifying events – divorce or legal separation and loss of dependent status under the plan.
  • The proposal clarifies the content and timing of this notice.
  • The proposal would require plans to have reasonable procedures for requiring employees and their families to give this notice and for setting time limits as to when it must be given.  Plans would be required to accept notices that meet the minimum content requirements of the proposal.

COBRA Election Notice:

  • Under the proposal, the COBRA election notice would contain all of the information individuals need to decide whether to elect COBRA coverage.
  • The election notice would have to describe available health plan options, premium payment requirements, the consequences of failing to elect COBRA, and how COBRA coverage could be extended due to disability or a second qualifying event.
  • The proposal also contains a model election notice that plans could use to comply with the election notice requirement.

Other Notices:

  • After receiving a notice of qualifying event from an employee or family member, plans would be required under the proposal to notify individuals whenever a plan determines that an individual is not eligible for COBRA.
  • The proposal would also require plans to notify individuals when their COBRA coverage is terminated earlier than the full time period for which COBRA must be made available.

Contact Information:

For questions about the proposed regulation, contact EBSA’s Office of Regulations and Interpretations at (202) 693-8523.


If you are considering a debit card reimbursement feature for your FSA plan the following article will be of particular interest.

IRS Issues Debit Card Guidance

The IRS issued its long-awaited debit card guidance in the form of Revenue Ruling 2003-43 (http://www.irs.gov/pub/irs-drop/rr-03-43.pdf). The ruling generally provides guidance on substantiation procedures for FSAs and HRAs and facilitates the use of electronic payment cards provided certain requirements are satisfied.

In a nutshell, the ruling upholds the existing IRS substantiation requirements: employee must certify that expense is eligible and not reimbursed from any other source; the incurrence of the expense must be substantiated by the medical provider; and the claim must be adjudicated. However, the ruling clarifies that the necessary certification, substantiation, and adjudication can occur electronically.

What type of participant certification is required? -- The participant must:

  • certify upon enrollment (and each plan year thereafter) that the card will only be used for eligible medical expenses;
     
  • certify that any expense paid with the card has not been reimbursed from any other source and will not be submitted for reimbursement under any other plan (this certification is included on the back of the card and reaffirmed each card swipe); and
     
  • acquire and retain sufficient documentation for any expenses paid with the card.


Is adjudication required for every health FSA or HRA claim?
Yes, in all cases. However, the adjudication may occur electronically.

Can an electronic card swipe serve as automatic adjudication?
Yes, it can, provided certain conditions are met. Generally, card usage must be limited exclusively to medical providers (i.e., by merchant codes). In addition, substantiation must occur via one or more of the following:

  • correlation of the amount of the expense to a specified co-payment under the plan (referred to as “co-payments”);
     
  • correlation of the amount of the expense to a recurring amount for a previously approved charge (e.g., a prescription refill) at the same provider (referred to as ”recurring expenses”); or
     
  • "real time substantiation" via tie-in with an independent third-party adjudicator (e.g., a pharmacy benefits manager) (referred to as “real-time substantiation”). After the fact audit sampling alone is not recognized as an adequate substantiation method.

Can conditional payments for charges, other than copayments, recurring expenses and real time substantiation, be made?
Yes, as long as claims are ultimately adjudicated. Adjudication may occur via the “old fashion way” (e.g., review of receipt for the medical services) or by EOB roll-over.

If a "bad" payment is discovered, must it be "recouped"?
Correction procedures must be in place if a “bad” payment is discovered (e.g., under the conditional payment mechanism described above). The ruling notes the following progression of steps:

§         the employer requires the employee to pay back the amount to the plan;

  • if unsuccessful, the bad payment is withheld from wages (to the extent consistent with applicable law); and
  • a claims substitution or offset approach (essentially withholding on otherwise valid claims) is undertaken. In addition, the employer must take additional steps to ensure no further violations occur (e.g. denial of access of card until amounts are recouped).

Is an IRS Form 1099 Required for Payments?
Generally yes where a 1099 is required for the particular payee. The ruling notes that payments must be reported by the employer.

What is the effective date of this guidance?
Employers using cards that provide after-the-fact audit sampling or sampling adjudication methods must comply with this revenue ruling as of December 31, 2003.

Copyright © 2003 by the Employers Council on Flexible Compensation

Who are California’s Uninsured?

Source:  “To Buy or Not to Buy:  California’s Non-Poor Uninsured,” a report by the California HealthCare Foundation and the Field Research Corporation.

According to a report by the California Health Care Foundation (www.chcf.org) 40% of California’s uninsured population earn more than 200% of the Federal Poverty Level.  That’s a monthly income of at least $1,477 for an individual and $4,044 for a family of six.  Take a look at some very interesting facts about this group.

Income and Spending:

  • Almost 70% are single and below age 40
  • 40% have a household income above $40,000 a year
  • 17% earn $50,000-$74,999 per year or more
  • 10% earn $75,000 per year or more
  • 40% own a home
  • 56% own a personal computer
  • 90% have purchased auto insurance, 46% homeowners’/renters’ and 37% life

Health Care:

  • 88% report being in good, very good or excellent health

In past 12 months:

  • 90% of health bills incurred were paid in full or paid in installments
  • 89% were satisfied with the care they received
  • 75% spend less than $300 on medical services
  • 42% used no medical services
  • 8% used medical services but were not charged

Health Care Increases Going to the Dogs

On the lighter side of the current health care insurance increases, a recent publication announced that the rates offered for Veterinary Pet Insurance through VPSI has had a 42.8% increase this year.  So, when we see the double digit increases on our medical renewals, at least we can be thankful we aren’t dogs.


Duration of Health Benefits for those on Workers Comp


There has been some dispute on whether an employer is required to maintain
health benefits for an employee who is out on a workers compensation claim.

The source of this confusion stems from California Labor Code section 132(a),
which makes it illegal to discriminate against a worker who suffers an injury
covered by workers comp. Recently the Workers’ Compensation Appeals Board (WCAB)
resolved the dispute by deciding that the federal Employee Retirement Income
and Security Act (ERISA) places employee benefit plans under federal regulation.
Therefore the state cannot require an employer to provide health benefits to
an employee it would not otherwise cover.

What should you do? We advise our clients to create and administer, within
your employee manual, a non-discriminatory policy defining whether an employee
who is out on any disability, not just workers comp, is eligible for any continuation
of health benefits. Any policies established should be in compliance with the
minimum requirements of FMLA/CFRA and pregnancy disability leave. You should
also make sure that whoever handles the COBRA administration, knows that a workers
comp claim is a “qualifying event” and takes the appropriate action.

Use of Social Security Numbers in California

The phasing in of California bill SB168 began July 1 2002. This bill was written
to help guard against identity theft and provide additional privacy protection.
As is the case with most new legislation, what the functional requirements are
and when are we required to comply, can be somewhat confusing. Essentially this
law prohibits the public posting of social security numbers and/or requiring
the use of social security numbers in accessing products or services. Since
most insurance company’s use the social security number as the individual identification
number, we will need to prepare ourselves for change. Our understanding of the
practical impact, for health care and insurance purposes, is as follows: Effective
1/1/03 Social Security numbers (a) cannot be publicly posted or displayed, (b)
cannot be required in any internet transmissions unless the connection is secure
or the number is encrypted, (c) cannot be required in accessing a website unless
a password or other unique personal ID number is also required, (d) other than
on forms or applications, cannot print an individuals number on any materials
that are mailed to the individual.
Any new individual or group contract issued
on or after 1/1/04 will no longer be allowed to print the individual’s social
security number on the ID card. Any contract Renewing on or after 7/1/04 will
no longer be allowed to print the social security number on the ID cards. While
we’re not aware of any providers not currently using the social security number,
the bill does include a provision that says if the number is not currently being
used, effective immediately no one can start using it. We will keep you posted
on any additional requirements or changes in the interpretation of this bill
and it’s requirements.


Relief from Filing Form 5500

Employers with less than 100 participants in their Section 125 cafeteria plans
received some administrative relief through a recent IRS amendment to the 5500
filing requirements. In the past any employer who maintained a Section 125 flexible
benefit plan, regardless of size, was required to file Schedule F attached to
a completed Form 5500. Under this new ruling, if you have less than 100 participants
in your 125 plan (this includes those participating in the premium only portion)
you no longer are required to make this filing. Furthermore, this ruling is
effective immediately and applies to all plan years for which information returns
have not been filed. This notice does not affect any other filings you are required
to make under Title 1 of ERISA.

Health Costs Still Soaring

Most employers are seeing the renewal increases, for their health benefits,
range from 25% to as much as 60%. Even CALPers, the largest health contract
purchaser in the state, has experience increases of 25% and 28% over the last
two years. With the economy still struggling, most employers are being forced
to pass at least part of the cost increases on to their employees. They are
doing this by either reducing the benefits through adding some form of hospital
co-payments or increasing the deductibles, and/ or increasing the amount the
employees themselves are charged for benefits. Recent national statistics show
that employee’s payroll deductions for medical coverage have gone up 50%. California
employers are seeing higher increases than many other parts of the country.
As we have stated in previous newsletters, California has been the leader in
“managed care” contracts that in the past has kept our health insurance costs
comparatively lower than the high cost of living would normally dictate. However,
with the number of IPA’s that have gone bankrupt and the hospital groups struggling,
many say these increases were inevitable. It may be some consolation that California
employers still pay a smaller amount, as a percent of payroll, for benefits
than the national average. Unfortunately we see double digit increases continuing
for the next couple of years.

California Conforms to EGTRRA

Recently California adopted legislation that brings the state tax statutes
into compliance with the new Federal Economic Growth and Tax Relief Reconciliation
Act of 2001. The new state provisions are retroactive to coincide with the federal
effective date and affects taxable income years on or after January 1, 2002.
One key benefits of these changes is the increased contribution limits people
are allowed to contribute to their retirement accounts. We are advising all
of our clients to review their contributions to make sure they are taking full
advantage of the increased limits.

More Employers Offering Long Term Care

During the 90’s the number of Americans purchasing Long Term Care insurance
more than tripled, and the number of employers offering LTC as a benefit to
their employees grew from a mere 135 to over 3,200 during the same time. Furthermore,
the federal government is poised to offer a Long Term Care insurance plan to
all federal employees, and their families. With the life expectancy of Americans
increasing, the need for assisted living facilities, nursing homes, home health
care, hospice and respite care, has skyrocketed. People who need the services
of a qualified facility are finding the cost to be in the area of $40,000 per
year. More and more of the “Baby Boomers” are seeing their parents in need of
these facilities and in many cases find it necessary to assist in the financial
burden. Many of the group contracts, allow the employees to extend lower premium
plans available through the group plans, to members of their immediate family,
including parents and grand parents. The rapidly increasing cost for traditional
employee benefits, such as medical coverage, has mandated that a larger portion
of the premiums be shared by the employees
. Employers are finding that offering
a relatively low cost benefit, such as Long Term Care, not only provides a tremendous
benefit to their employees but also eases the “sticker shock” of the additional
contributions required for the other benefits. For more information, please
feel free to contact us at Lafayette Square Insurance Services, Inc. for more
information.

Should You Take a Reduced Early Social Security Benefit?

If you will still be receiving some earned income, you should rethink taking
a reduced Social Security benefit, at age 62. While the Federal Government reduced
the age (from 70 to 65) at which you can have earned income without any penalties
to your SSI benefit, the reduction could still be substantial. Prior to your
full retirement age your Social Security benefit is reduced $1 for every $2
you earn over $11,280. In your full-retirement year, the government will deduct
$1 for every $3 you earn over $30,000 and only in the months prior to your 65th
birthday. As an example, if you turn age 65 in August and are making $5,000
per month you will have earned $35,000 by your birthday. This is $5,000 over
the limit so they would reduce your Social Security benefit by one third of
that $5,000, or $1,667. (You can test the ways that collecting benefits at various
ages would affect your payout with an online calculator at www.ssa.gov/fetire2/retcalc.htm)

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Health Insurance Increases 18% CPI Increases 2.8%...WHY?

Most of us have seen double-digit increases on our health insurance plans over
this last year. According to the National Health Care Trend Survey, this soaring
rate of inflation is not going to let up. A comment frequently heard from people
in a variety of different industries is “The CPI (Consumer Price Index) is under
3%, and if I tried to raise my prices by over 10% to 15%, I’d be out of business.
How do the insurance companies get away with this?”

In addressing this problem it’s important to identify whether this is truly
a cost increase across the board, or is it at least in part, a shifting of the
cost from one area to another. One such occurrence, that those outside the medical
community are generally not aware of, is the lowering of reimbursements made
by Medicare. Hospitals are required to accept Medicare payment as payment in
full. If Medicare reduces or even freezes the level of benefits paid, the hospital
needs to make up that loss of revenue from the non-Medicare patients. The largest
user of medical services is the portion of our population eligible for Medicare.
Consequently, a 4% reduction in Medicare reimbursements could conceivably require
a 10% increase from the private sector in order to make up the difference.

Another specific area of health care that happens to have the highest increase
in cost is that of pharmaceuticals. There are two areas that are quite apparent
when addressing the almost 20% projected increase in cost for prescription drugs.
One is the obvious increase is the usage of prescription drugs.

Not only are some treatments that used to require hospitalization now being
treated
pharmaceutically at home, but also many “healthy” people are also taking
prescription drugs such as Prozac and Viagra to improve their quality of life.
Another driving force in this arena is the increase in Generic Drugs. For years
one of the largest costs in the pharmaceutical arena has been that of research
and development. The actual production costs are fairly minimal and so in the
past the drug companies could afford to recoup their R & D cost over a longer
period of time. With the rapid increase in generic equivalents and the ongoing
push to allow their introduction sooner, the companies that develop these modern
miracles are forced to recoup these costs over a shorter period of time.

Still another contributor to the increases is the continual stream of new legislation
mandating what and how certain illnesses or conditions should be covered. Every
time a new piece of legislation is introduced and passed it brings with it a
cost. As an example, last year’s Mental Health Parity Act required insurers
to build in an estimated 1% to 2% increase in premium rates. We don’t think
anyone calls these legislative mandates “bad” but they do have a price.

Is there any good news in all this? Well if putting a little different perspective
on the circumstances qualifies, then the answer is yes. Looking back 20 years,
the average cost of fringe benefits to an employer was about 27% of payroll
and the cost for medical insurance alone was a little less than 10% of payroll.
If we look at the proportional cost of medical benefits and in fact fringe benefits
as a whole, we believe we’ll discover that those percentages are still about
the same. Like we said, it doesn’t change the size of the check we need to write
each month but it may reduce the “writers cramp” a little.

More Health Care Costs Increase

CHICAGO, Dec. 11 (Reuters) - The average cost of health care nationally, for
consumers and employers who help pay for employees’ health insurance, is expected
to go up by 11% next year. This is on top of an 8.1% national average for this
year. This will bring the average health care cost per employee to over $4,900.

Several reasons are to blame for the rise in health care costs including an
aging population, rising prescription drug costs, and pressure on companies,
by their shareholders, to improve profit margins.

About 40% of employers in the survey said that they will increase their employees’
contribution levels in 2001 and 17% said they will raise deductibles, co-payments
or out-of-pocket maximums. A notable number of employers in the survey also
terminated their medical plans for retirees. The number of large employers offering
medical care for retirees who are not eligible for Medicare fell from 35% to
31% in 2000, and from 28% to 24% offering coverage to Medicare-eligible retirees.

RX Costs Going Higher– Why?

Some reports are saying that prescription drug expenses now represent about
20% of the total benefit dollar being paid out. This is up 100% from where it
was just five years ago. Several California HMO’s are calling for a 250% increase
for the pharmacy portion of their benefits.

Five contributors to escalating cost:

 

  • Huge direct marketing and advertising campaigns urging consumers to “ask
    your doctor”, and they are. In some markets the ad campaigns for drugs are
    more frequent than those for automobiles.
  • Increasing number of new drugs. There are currently over 400 new drugs awaiting
    FDA approval.
  • Direct-risk contracts with physicians, including prescription drugs are
    not being renewed
    , placing additional pressure on insured and self-insured
    plans.
  • Many conditions that were previously treated by surgery or hospitalization
    are now treated with expensive drug-therapy-intensive disease management programs.
  • Our aging population. With people living longer, the number of elderly will
    soon constitute over 50% of our population. This group of people is by far
    the highest user of prescription drugs.

There are currently no feasible solutions to these rising costs. We hope, by
keeping you informed of the causes of the problem, that the sting of paying
for them is somewhat lessened.

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The HMO Chaos

The California managed care system continues to be in turbulence. The contract
negotiation difficulties between insurance carriers and their networks of hospitals
and providers appear to be here for the unforeseen future. As you may have read
the California Public Employees Retirement System (CalPERS) has dropped four
of the system’s 10 HMO’s (Aetna, Cigna, Lifeguard and Maxicare). Stanford has
announced they are canceling their contracts with all capitated HMO plans and
a number of insurers have filed a notice with the Department of Managed Care,
to withdraw their HMO product from rural areas of the state.

As we have mentioned earlier, the hospitals and doctors can no longer afford
to maintain their practice with the low capitated levels of reimbursements they
have been receiving from the carriers. The direction CalPERS is taking, with
their benefit plan offerings, will cause their estimated costs to increase from
6% to 24%. Since CalPERS is the largest purchaser of health insurance in the
country, other employers should expect even larger increases. To avoid the disruptive
confusion of the HMO’s, many employers are moving back towards the PPO plans,
or at least adding a PPO option that their employees can “buy up” to. The slower
economy we are currently dealing with, coupled with the substantial increase
in the cost of benefits, almost mandates a greater sharing of the cost by employees.

Late Fees on Premium Payments

Blue Cross has announced that they will now charge a $20.00 late fee for any
premium payments not received by the 15th of the month. The reinstatement fee
has been changed to a flat $50.00 in lieu of the $10 per enrollee previously
charged. The rules regarding the reinstatement of coverage after cancellation
for late payment has also tightened up. It should not be assumed that you will
always be able to reinstate your coverage. Is this another sign of the times?
We feel it is. Blue Cross has joined HealthNet, who is already very strict on
their rules regarding late payments and subsequent cancellations, and we feel
other carriers will be following suit. A word to the wise is to avoid late charges
and cancellations by submitting premium payments on time.

Good News from Sutter and Blue Shield

Sutter, one of Northern California’s largest medical providers, and Blue Shield
of California have reached an agreement in their 2002 contract negotiations.
In a climate that has agreements being reached at the last minute of the deadline,
it is a welcome change to have a settlement, months before the due date. It
also has been reached in time for the annual fall open enrollment period many
workplaces have.

Provider Update Low

Reimbursements Continue to Restrict Health Care Availability—Palo Alto Medical
Foundation is, for an indefinite period of time, no longer accepting new patients
for “basic care”. The high cost of housing coupled with low reimbursements to
the physicians has made it extremely difficult to recruit new doctors. This
last year, the Internists, Family Practitioners, and Pediatricians at the Palo
Alto Foundation, have served, on average, twice the normal number of patients.
This overload has brought about a frustrating three-month waiting period for
people wanting to schedule their regular, routine physicals. Since several other
large groups have closed, there are not many options left for many of the Bay
Area Residents.


New 401k Regulations & Limits

IRS Code

What it Means

2001

2002

2003

 402(g)

 Increases  amount a  participant  can defer  each year.

 $10,500

 $11,000

 $12,000  (increases  $1,000 each year to  $15,000 in  2006, then  indexed in  $500 increments)

 415

 Increases  total  amount of  deferrals, matching and  profit- sharing  dollars that  can be added to a  participant  account each  year.

 Lessor of  $35,000 or

 25% of  compensation

 $40,000 or

 100% of  compensation

 Indexed in  $1,000  increments  or

 100% of  compensation

 Catch Up  Contributions

 Increases  amount  participants  over 50 can  defer each  year over 402(g)  deferral limit.

 n/a

 $1,000

 $2,000  (increases  $1,000 each year to $5,000  in 2006, then  indexed in  $500  increments)

 Top Heavy  distribution  look-back period

 Limits look -  back for  distributions and  terminations

 5 years

 1 year (other than in-service  distributions)

 Start-up  Credit

 Determination  Fees

 Gives small  employers  (fewer than  100 employees)  two  incentives to start plans.

 n/a

 

 $125- $1,250  fee

 

 Tax credit equal to 50% of  qualifying start-up costs (up to  $500) for first three years.

 No fee for requests made within  first 5 years of plan’s existence.

 Low-income  savers

 Adds tax  credit of up  to $1,000 for
qualifying  adjusted  gross  incomes.

 n/a

 Tax credit up to 50% on up to  $2,000 on deferrals per year.

 Safe Harbor  Hardship  withdrawal  suspension

 Reduces  length of  suspension  after Safe  Harbor  withdrawal.

 12 months

 6 months

 Rollovers

 Encourages  rollovers  among  various types of retirement  plans.

 Limited by  plan type or  IRA

 

 All rollovers between IRA,  457, 403(b), 401(a) and 401(k)  plans permitted.

 Vesting  Schedules

 Lowers the  maximum  vesting for  matches.  

 5-year cliff  or  3/20  (7- year schedule)

 

 3-year cliff or 2/20 (6-year  schedule) on vesting for  matching contributions.

 Loans to  owners

 Okays loans to partners,  SubS owners and sole  proprietors.

 n/a

 

 Loans allowed to subchapter S  owners, partners and sole  proprietors.

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Happenings

You may have heard things are stirring up again between Blue Cross, Redwood
Empire Medical (REMG) of Santa Rosa and many of the specialists in the Santa
Rosa
area. In fact, Blue Cross has now moved to terminate REMG as a contracted
provider group 7/1/00. If your PCP is in REMG there are two possibilities: (1)
if that PCP belongs to another medical group, you may keep your PCP and change
the group only; (2) if that PCP is not a member of another provider group, you
need to pick a new PCP by 6/15/00 or Blue Cross will do it for you.

On another front, Blue Cross and Catholic Hospitals West are at loggerheads
over contract negotiations. Last year this happened with Blue Cross/Sutter Hospital
group (more on Sutter in a minute), but a settlement was reached at the last
minute. A termination of the Blue Cross/Catholic Hospital’s contract would result
in huge dislocations of members in Northern California. We’ll keep you posted
or you can call us for updates.

Now, about Sutter Hospital Group (which includes Alta Bates locally). Aetna
and Sutter are at a crossroads. As we write this they have been in day long
negotiations. Aetna and Prudential have advised insureds that they may get new
PCP’s on 7/1/00. Alta Bates, and other Sutter Hospital Group members, have advised
members to put pressure on your agents and the companies to give us what we
need to survive.

At Lafayette Square we see these “happenings” as tolling bells. The fabric
of the managed care system is being pulled to pieces. Doctors and hospitals
want more money to provide care. Members want lower rates and full access to
all that medical technology is promising (a little compassion and better access
to their doctors would help too). Insurance Companies and Managed Care Providers
would like to please both (impossible?) and make a profit. Where will we end
up? We’re not sure, but we are sure we’re on the move.

Have You Shopped Online?

Have you heard you can buy all kinds of insurance online? Promise: “No broker
to talk to.”
An interesting factoid: prices online with no broker are the same
prices from Lafayette Square and you get our service: awareness of the marketplace,
who’s merging or will merge, whose network matches your employee’s MD’s, plan
design for effective benefits and more.

Maybe the slogan should be: “Shop Online - Buy From Your Broker - Lafayette Square.”

Blue Shield of CA Revises Small Group Plans

Please be advised that effective 7/1/2000 Blue Shield of California is changing
their plan designs. These changes will take effect for each group on their anniversary
date, starting with 7/1/00.

Blue Shield has sent out notices directly to their insureds on or around May
15th. The packet, which was sent directly to the employer, outlined the changes
thoroughly and advised how the transition is to take place.

However, we would like to take this opportunity to remind our valued customers
of some of the major changes that are forthcoming.

 

  • Changes will take place effective on your anniversary date, starting 7/1/00.
  • No changes to HMO plan designs.
  • Elimination of the Shield Select Plans which was a 3 tiered plan: 90% for
    Select Providers, 70% for Preferred Providers and 50% for Out of Network providers.
  • New PPO Plan Designs to provide a more standard 2 tier plan: 90% for Preferred
    Providers and 70% for Out of Network Providers.
  • Fixed dollar co-pay amounts rather than a percentage co-payment for many
    in-network services.

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What Happened To My Medical Carriers Network of Doctors?

You’ve undoubtedly noticed there has been numerous changes to the networks
of medical providers. A large number of these changes have to do with the fiscal
condition of the IPA’s the doctor’s belong to. In our on going effort to keep
our client’s apprized of any contract negotiations and / or financial problems
involving IPA’s and the insurance carriers; it has become apparent that a large
number of people are unclear of what an IPA is and what they do.

An Independent Practice Association (IPA) is exactly what the name indicates;
an association that various doctors and groups of doctors belong or subscribe
to. To understand their purpose requires a little history lesson. Back when
“managed care” was still relatively new, the administrative duties and the contract
negotiations with all the myriad of insurance companies was becoming too burdensome
for individual practices to handle. This gave rise to groups of individual practices
banding together in an effort to maximize their bargaining power and administrative
efficiency. Over the years these IPA’s have grown to where virtually all doctors,
who want to be on an HMO or PPO list, must belong to an IPA.

The power of these IPA’s has also grown over the years. Now the IPA’s don’t
just handle the contract negotiations but also the billings as well as approving
the referral of a patient to a specialist.

Many people think that the insurance carriers pay their doctors directly when
in fact most of the monies are paid to the IPA , which then distributes the
money to the doctors. Often times this is why you may get a notice from your
doctor’s office that it hasn’t been paid while the insurance company says they
issued a check weeks ago. The payments have been held up in “IPA Limbo”.

The hope was that these associations would also be profit centers in themselves.
Unfortunately, recent reports have indicated that if an IPA shows a profit of
a tenth of one percent, it is among the more successful ones out there. The
answers to these problems are difficult. The consumer is tired of paying the
high price of medical insurance. The medical community says it needs more money
from the insurance carriers. The insurance carriers are continually required,
by new legislation, to expand services while trying to avoid raising premiums
even higher than they currently are. Hence, the never-ending merger of insurance
carriers in an effort to use economies of scale to accomplish this.
What do
we think the answer is? The reception on our crystal ball is a bit fuzzy, but
stay tuned for future updates.

Domestic Partner Benefits: Overview

In recognition of the growing number of domestic partner relationships, and
to remain competitive and develop employee goodwill,
many employers have implemented
benefit programs for their employees’ domestic partners. What follows is an
overview of things you should know.

Eligibility: Buck Consultants advises employers to include a “verification
clause” in a domestic partner benefit plan. The status of a domestic partner
is usually established through an affidavit process that requires an employee
to attest that the domestic partnership has existed for a minimum amount of
time (e.g. two years).

Cost considerations: Employers offering domestic partner benefits have
not experienced skyrocketing health care costs. Studies reveal no disproportionate
cost increase following the addition of same sex partners to an employers health
care plan.

Benefits: Employers may provide the same benefits to domestic partners
that are provided to a spouse or dependent, or the benefits may be limited to
specific benefits such as health insurance, and/or dental insurance. The City
and County of San Francisco requires all offered benefits to be made available
to a domestic partner.

Cafeteria Plans: The cost of domestic partner health coverage may not
be paid
on a pretax basis or by using flexible credits. These rules apply because
amounts paid on behalf of a domestic partner for health costs are not deductible
as medical expenses on the employee’s income tax return.

COBRA: The Consolidated Omnibus Budget Reconciliation Act of 1985 (COBRA)
requires employers to offer continued health coverage to qualified beneficiaries.
Since a domestic partner would not generally be a qualified beneficiary under
COBRA, this coverage is not required to be offered.

FMLA: Employers that provide domestic partner benefits are not required
to offer leaves of absence under the Family and Medical Leave Act (FMLA) for
the care of a domestic partner who has a serious health condition.

HIPAA: The Health Insurance Portability and Accountability Act of 1996
(HIPAA) requires employers to provide certifications of health coverage when
covered employees and their dependents lose coverage for any reason. Since a
domestic partner would not generally be a qualified dependent under HIPAA, providing
certificate of coverage is not required. However, offering a certificate of
coverage is suggested to help the domestic partner avoid pre-existing health
issues on their next health plan.

Spencer’s Benefits Reports 5/26/00

Getting Lab Bills Paid

Have you been having problems getting your lab bills paid? If you are an HMO
participant, it may be because the lab billed your insurance incorrectly. Please
note the IPA or Medical Group, not the insurance carrier, pays most providers,
including labs, for professional services. The insurance carrier is responsible
for the facility charges. If you receive a bill from the lab, here are some
helpful hints to assist in getting it resolved.

Do not ignore it. You don’t want to risk getting turned over to collections.
Find out how the lab company billed your insurance.

HMO’s: Your Medical Group gets billed. PPO’s: Your Insurance Carrier gets billed.
POS’s: Depends on level: HMO (See above); PPO: (See above).

As with all claims, it is vital that you document the date, who you talk to,
phone number and extension, and the result of the phone call. If you need assistance,
please contact us.

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