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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.
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.