Health Policy Latest News
NBCH SUBMITS COMMENT LETTER TO THE IRS ON THE UPCOMING EXCISE TAX NOTICE
The IRS and Treasury released a Notice related to the upcoming excise (Cadillac) tax, specifically around the definition of applicable coverage, and how costs will be calculated. NBCH staff, in consultation with the Government Affairs Committee, have submitted a comment letter for your perusal. We strongly encourage each coalition to take action on this,
and there are a couple ways you may consider doing so:
Send a letter directly from the coalition by
replacing the information about NBCH with your own
Distribute to your employers and ask them to use
this as a template to draft their own comments
Note the deadline for any
submission is THIS FRIDAY, May 15. Comments may be submitted
electronically, using subject line IRS Notice 2015-16, directed to email@example.com
EMPLOYER'S ROLE IN 'POST-EXCHANGE' WORLD
Bruce Sherman, medical director of Employers Health, explains the employer's role in managing employee health in the health care reform environment built upon private and public insurance exchanges. Watch the video here.
NBCH SUBMITS COMMENT LETTER ON EMPLOYER REPORTING REQUIREMENTS UNDER THE ACA
NBCH, on behalf of its members, has submitted a comment letter to the Internal Revenue Service (IRS) on two proposed rules regarding required reporting employers must provide both to the IRS and to employees. The two rules describe the proposed process for employers to report to the IRS regarding their compliance with the employer shared responsibility provision ("pay or play") and the minimum value of the coverage provided. The full letter can be found here.
NBCH SUBMITS COMMENT LETTER ON MINIMUM VALUE PROPOSED RULE
NBCH, on behalf of its members, has submitted a comment letter to the Internal Revenue Service (IRS) on the proposed rule regarding minimum value of eligible employer-sponsored plans. The full letter can be found here.
NBCH AND THE COMMONWEALTH FUND RELEASE FIRST BRIEF IN NEW "HEALTH REFORM & YOU" SERIES
NBCH is pleased to partner with the Commonwealth Fund to produce a series of briefs titled "Health Reform & You". Click here to see the first brief on the importance of primary care.
NBCH SUBMITS COMMENT LETTER ON "PAY OR PLAY" PROPOSED RULE
NBCH, on behalf of its members, has submitted a comment letter to the Internal Revenue Service (IRS) on the proposed rule regarding the employer shared responsibility provisions set forth in Section 1513 of the ACA. The so-called “pay or play” provisions impose new shared responsibility requirements on employers regarding the offering of health coverage by employers to their full-time employees. NBCH’s letter highlights the leadership role employers have always played in offering affordable health insurance to their employees and families. It goes on to express concern that these new ACA requirements will be overly burdensome and complex for employers, causing them to consider alternatives to offering traditional employer-sponsored health insurance. The full letter can be found here.
NBCH SUBMITS COMMENT LETTER ON WELLNESS PROGRAM INCENTIVE CHANGES
The ACA adds new section 2705 to the Public Health Service Act, which makes changes to existing HIPAA regulations on employee incentives in employer-sponsored wellness programs. The new section allows employers to increase from 20 percent to 30 percent the maximum premium differential for employees who satisfy a specified goal under a health-contingent wellness program. NBCH submitted a comment letter to the Departments of Labor, Treasury, and HHS, which are jointly responsible for implementation of this provision. The letter applauds the Departments for applying the new provision to all plans, regardless of grandfather status, while cautioning that the application of "reasonable alternative standards" employers must put in place to ensure health-contingent wellness programs are fairly administered not be allowed to become so burdensome for employers that they are discouraged from offering health-contingent wellness programs. The full letter can be found here.
NBCH SUBMITS COMMENT LETTER TO OPM ON MULTI-STATE PLAN PROGRAM
The ACA gives the Office of Personnel Management (OPM) the authority to "stand in the shoes" of individual state health insurance exchanges (both state-run and federally-run) to determine Qualified Health Plan status for issuers selling on the exchanges. For large, nation-wide issuers, OPM's Multi-State Plan Program (MSPP) will greatly reduce administrative burden and allow for easier streamlining of efforts, both for exchanges and for issuers. OPM recently published a proposed rule describing the parameters of the MSPP, and NBCH submitted a comment letter advocating for the use of eValue8 as a valuable plan management tool to ensure these large, nation-wide issuers are held to high standards of accountability for providing high-value care to exchange customers. See the full letter here.
NBCH RESPONDS TO CMS RFI: HEALTH CARE QUALITY FOR EXCHANGES
NBCH has responded to a CMS request for information on what kind of quality data should be gathered and used in health insurance exchanges. See the full letter here.
NBCH SUBMITS COMMENT LETTER TO HHS ON TRANSITIONAL REINSURANCE PROGRAM
NBCH, on behalf of its members, has submitted a comment letter to HHS on the proposed rule for the Transitional Reinsurance Program (TRP). The TRP is a program under which per capita fees will be collected from employers to provide reinsurance to issuers in the new health insurance exchanges to help mitigate the uncertainty of the risk in that market. NBCH's letter commends HHS for proposing flexible standards and options for counting plan enrollees, but expresses concern about the unanswered questions still remaining regarding issues such as treatment of disease management and wellness programs, and the interaction between the federal TRP and state high-risk pools.