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Small Group ACA Presentation Looking to 2015 and Beyond. October 2014

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Small Group ACA Presentation

Looking to 2015 and Beyond

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Key Terms

 ACA = Affordable Care Act  FTE = Full Time Equivalent

 GF = Grandfathered Health Plan  GM = Grandmothered Health Plan  ER = Employer

 EE = Employee

 MCR = Modified Community Rates

 PEO = Professional Employee Organization

 MEWA = Multiple Employer Welfare Arrangement  SF = Self Funding

 DOL = Department of Labor  IRS = Internal Revenue Service  SPD = Summary Plan Description

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Medical Plans for Small

Employers

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Small Employer Designation

 Less than 51 full time & Full Time Equivalent (FTE)

 No Employer requirement to offer coverage

 No Employer requirement to meet affordability

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I Have Less than 51 Employees

What are my medical plan options?

 “Grandfathered” Plans

 “Grandmothered” Plans

 ACA Plans

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“Grandfathered” Plans (GF)

 Very few carriers offer GF plans

 Plans in place since 2010

 Employer & carrier extremely limited as to any benefit changes

 $5 OV increase

 5% Deductible increase  5% Out of pocket increase

 Payroll cost to employee almost “fixed” in nature

 Employee share % cannot increase by more than 5%

 Avoids Modified Community Rates (MCR) & Essential Benefit

Provisions

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“Grandmothered” Plans

 D.C. ’s political solution to employer push back & carrier

apprehension

 Modified solution to “If you like your plan, you can keep it”

 Avoids Modified Community Rates (MCR)

 More renewal options than GF plan

 Multiple carrier interpretations about options at renewal

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Old Premium Rating Methodology

 Applicable to both Grandfathered and Grandmothered

plans

 Premiums could be adjusted due to:

 Male/Female  Age

 Company location  Company SIC code

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MCR

Modified Community Rates

 Up to 18 regions in state of Ohio are allowed

 Rates are uni-sex

 Only premium modifiers allowed are:

 Age

 Zip code  Tobacco use

 In essence MCR has created large, state wide, high-risk

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Premium Rating Calculations

 Old systems allows up to a 6 to 1 ratio*

23 year old male $125

64 year old male $750

Total monthly premium $875

 New MCR under ACA rules requires a 3 to 1 ratio

23 year old male $219

64 year old male $656

Total monthly premium $875

*Approximate Ratio

6 to 1 Ratio

69% increase 12% decrease

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ACA Plans

 MCR in effect

 Smaller subset of GF & GM plans

 Some carriers also have limited networks to

keep costs down

 Once ACA plan is elected, GM &GF plans are no longer

available to Employer, i.e. “no going back”

 Guarantee issue still required of carriers

Ohio one of 5 states to implement the “untested” SHOP

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Alternatives to ACA Plans

 PEO – Professional Employee Organization

 Partially Self Funded Plans

 MEWA – Multiple Employer Welfare Arrangement

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PEO

Professional Employer Organization

 Employer becomes co-employer with PEO

 Employees could become direct employees of PEO

 PEO management fees apply

 Payroll taxes & worker’s compensation also transfer to

PEO at the PEO rates

 May have better benefit options and rates due to being

part of large group

 PEO can be fully insured or self funded

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Partially Self funded

 Employer determines risk to “take on”

 Employer purchases stop loss protection, specific &

aggregate

 Potential run out issues could exist in some carrier

contracts

 Employer can always move to ACA plan at renewal

although contract terms may leave employer exposed to additional financial risk at contract termination

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Self Funding Cost Indicators

Fully Insured Self Funded

Federal taxes $$ $ + State taxes $ - + Admin charges $$ $ + Risk pool $ - + Expected claims $$$ $$$ = Total expenses $$$$ $$$ + Claims corridor (10-25%) - $ + Run out - $ + Profit $ ??

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Self Funding Contract Type-12/12

January 12 Months December

Claim incurred

ER responsible with no Stop Loss protection

Claims processed & paid

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Self Funding Contract Type-12/15

January 12 Months December

Claim incurred

ER responsible with no Stop Loss protection

April Claim processed and paid – Stop Loss

protection in place

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MEWA

Multiple Employer Welfare Arrangement

 Numerous employers joining forces to share risk/rewards

 Usually billed at mature rates, i.e. no run out issues  Needs the safety of rock solid stop loss carriers &

agreements to protect employer from unexpected risk

 Exhaustive state and federal oversight exists today

 Sorted past a challenge to overcome, bad perception in

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MEWA Funding

 Modified self funding

 Monthly funding rates generally include all SF components  “Walk Away” contract

 Pooled resources are the key to cost controls & pricing models  Each group is medically underwritten, creating rates indicative of

underlying risk for each group  Age/sex factors apply

 SIC code could apply

 Superior contract compared to stand alone self funding arrangements

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The ACA Balancing Act

The Affordable Care Act has created significant government oversight, regulation and employer challenges.

 Regulatory enforcement courtesy of the Internal Revenue

Service (IRS) & The Department of Labor (DOL)

 Compliance issues are numerous but easily dealt with

 Summary Plan Description (SPD) continues to be tops on the

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ERISA Compliance

 Summary Plan Description

 Must be furnished within 120 days of the start of ERISA Plan  Must be furnished within 90 days of Participation

 Updated SPD must be furnished at least once every 5 years to

all covered Participants

 Method:

 To be furnished in a way “reasonably calculated to ensure actual receipt of the material” using a method

“likely to result in full distribution”

A Carrier “Certificate of Coverages” is NOT an SPD A Carrier “Certificate of Coverages” is NOT an SPD A Carrier “Certificate of Coverages” is NOT an SPD

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How to get your SPD

 Fulfill the ERISA requirements for an SPD and avoid penalties  Alpha client cost $450/up fee waived (regularly $650 +

set-up fee)

To receive enrollment kit and discount email [email protected]

Includes:

 Separate Plan Document and Summary Plan Description (wrap document)  ERISA and Affordable Care Act Notices at no extra charge

 Summary of Material Modification

 Instructions on how to distribute information to employees

 Email alerts regarding changes to ERISA or IRS requirements that could impact Wrap

SPD and Plan Document compliance

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The Alpha Group specializes in the design and implementation of employee benefits plans, including retirement plans.

Established in 1988, Alpha provides Insurance Products and Consulting Services to over 1100 businesses in Ohio. Our client base ranges from individual contracts to those with well over 1,000 employees in numerous states. Alpha is one of the top 15 Insurance Agencies in Northeast Ohio as reported by Crain’s Cleveland

Business.

Employee Benefits • Business & Personal Insurance • Retirement Plan Services HR Consulting Services

John Wain, Principal

The Alpha Group Agency

4200 Rockside Road, Suite 300 Cleveland, Ohio 44131 216.520.3300 |800.886.3315

[email protected] | www.TheAlphaGA.com

References

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