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Posts Tagged ‘ACA Section 1311(b)(2)’

Measures would allow individuals to purchase small group plans sold by DC health benefit exchange and federal employee plan to fill gaps in state individual markets

June 5th, 2017 No comments

Two measures were recently introduced in Congress to address gaps in the non-group medical insurance market by allowing individuals and their family members to buy into small group plans sold through the District of Columbia’s health benefit exchange’s Small Business Health Options Program (SHOP) if their state health benefit exchange offers no plans where they live.

The Health Care Options for All Act (S.1201, McCaskill) would require the Office of Personnel Management (OPM) to establish a mechanism for their enrollment. A companion measure to S.1201, H.R. 2770 (Loebsack) was introduced in the House June 2; text for the bill is not yet available. The DC SHOP currently offers coverage to members of Congress and their staffs as required by the Patient Protection and Affordable Care Act. The District of Columbia health benefit exchange, DC Health Link, is reportedly opposed fearing the proposal if enacted would turn the DC exchange into a de facto national high risk pool.

Section 1334 of the ACA authorizes OPM to contract with health insurance issuers or a group of affiliated plan issuers to offer plans in all states as of this 2017. While the intent is to ensure exchanges can offer plans in all areas, the “multistate plans” authorized by Section 1334 are available in less than half of the states.

The bills could raise objections from health plan issuers since they broadly organize their product lines as employer group or non-group (individual) coverage and risk rate, price and establish provider networks separately for each. In addition, the Affordable Care Act segregates small group and individual coverage into separate statewide risk pools. However, states may merge their individual and small group markets under Section 1312(c)(3) of the law “if the State determines appropriate.” ACA Section 1311(b)(2) also affords states the option to merge their individual and SHOP exchanges.

Another measure introduced in early May, (H.R. 2400, Issa) also disregards the distinction between the group and non-group market segments by allowing individuals who are not federal employees to enroll in the Federal Employees Health Benefits Program.

 


Need a speaker or webinar presenter on the Affordable Care Act and the outlook for health care reform? Contact Pilot Healthcare Strategies Principal Fred Pilot by email fpilot@pilothealthstrategies.com or call 530-295-1473. 

ACA small group market changes for 2016 could potentially benefit SHOP

May 1st, 2015 Comments off

The Patient Protection and Affordable Care Act holds two significant changes for the small group market taking effect for plan year 2016:

  • A mandatory definition of “small employer” as those employers with 100 or fewer full time equivalent (FTE) employees. Section 1304(b)(3) of the Affordable Care Act afforded states the option – which all exercised – to set the metric at 50 or fewer employees for plan years 2014 and 2015.
  • The delayed phase in under 2014 federal transition relief guidance of the large employer shared responsibility mandate. Under the guidance, the requirement that employers offer most employees health coverage meeting minimum benefit and affordability standards encompasses employers with 50-99 FTE employees starting in 2016.

Both alter the post-Affordable Care Act landscape of the small group market starting next year by expanding its parameters and providing greater incentive for small employers to offer health coverage. What remains to be seen is whether they will operate to expand small employer participation in the Small Business Health Options Program (SHOP) that all state health benefit exchanges must have in place unless they opt to combine their individual and small group exchanges as authorized by ACA Section 1311(b)(2). SHOP enrollment has been very weak in nearly all states relative to small group market as a whole.

A larger and more compulsory small group market could potentially boost SHOP’s prospects. But it won’t address the lack of strong economic inventive for small employers and their brokers to engage with the SHOP. The SHOP is predicated on pooling the purchasing power of small employers to drive down premiums that many small employers perceive as unaffordable. Gaining that purchasing clout with small group health plan issuers requires SHOPs first bring a lot more covered lives to the bargaining table – the classic chicken and egg conundrum.

Meanwhile, 17 business groups and the National Association of Health Underwriters have asked the U.S. Department of Health and Human Services in a February 18, 2015 letter to postpone implementation the 2016 mandatory definition of small employer to 100 or less employees to 2018, warning it would produce market disruption among health insurers that could limit employer coverage options as well as potentially lead to premium increases.

 


Need a speaker or webinar presenter on the Affordable Care Act and the outlook for health care reform? Contact Pilot Healthcare Strategies Principal Fred Pilot by email fpilot@pilothealthstrategies.com or call 530-295-1473. 

California health benefit exchange rebrands SHOP, possibly setting stage for merger of individual and small group exchanges

April 20th, 2015 Comments off

California could be setting the stage to merge its individual and small business health benefit exchanges by moving to rebrand its Small Business Health Options Program (SHOP) under the brand name of its individual exchange, Covered California. It will be dubbed Covered California for Small Business, according to this report by the Sacramento Business Journal.

State health benefit exchange SHOPs serve small employers — currently those employing 50 or fewer employees and those with 100 or less starting for plan years beginning in 2016.

Section 1311(b)(2) of the Patient Protection and Affordable Care Act gives states the option to merge their individual and SHOP exchanges. States may also merge their individual and small group markets under Section 1312(c)(3) of the law “if the State determines appropriate.” California law establishing the state’s exchange mandates it report to the Legislature by December 1, 2018, on whether to exercise that option taking into account the potential impact on premium rates paid by individuals and small employers in a merged market as compared to keeping the markets separate.

 


Need a speaker or webinar presenter on the Affordable Care Act and the outlook for health care reform? Contact Pilot Healthcare Strategies Principal Fred Pilot by email fpilot@pilothealthstrategies.com or call 530-295-1473. 

Floor of small group market may be rising

November 3rd, 2014 Comments off

The small group market may be undergoing a redefinition. Section 1304(b(2) of the Patient Protection and Affordable Care Act defines small employers as those having between 1 and 100 employees. (Through 2015, states have the option to set the upper limit at 50 employees.)

The marketplace could be raising the single employee floor on a de facto basis, according to this Bloomberg story reporting those working for small employers are increasingly purchasing individual coverage though state health benefit exchanges. The shift is accelerating among the smallest employers, Ana Gupte, an analyst at Leerink Partners LLC, told Bloomberg, adding it’s “happening faster than expected.”

The implication is the low end of the small group market – generally defined as organizations with fewer than 10-20 employees — is being cannibalized by the individual market, where the incentives for participation are far stronger. That would effectively change the practical definition of the small group market to a range of between 10 or 20 and 100 employees.

How this will affect state small group markets over the next few years remains to be seen. It could adversely impact the small employer side of the state exchanges — the Small Business Health Options Program (SHOP) – by significantly shrinking the pool of small employers that might potentially enroll. That could prompt all but the largest states to exercise their option under Affordable Care Act Section 1311(b)(2) to merge their individual and SHOP exchange functions. States also have the option starting in 2017 to offer large group plans on their exchanges as allowed under Section 1312(f)(2)(B)(i). But with the growth of private exchanges in the large group market, it’s doubtful the public state benefit exchanges would be appealing to large group plans.

 


Need a speaker or webinar presenter on the Affordable Care Act and the outlook for health care reform? Contact Pilot Healthcare Strategies Principal Fred Pilot by email fpilot@pilothealthstrategies.com or call 530-295-1473. 

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