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NBCH POLICY ALERT: H.R. 2050

NBCH is providing this information as an education resource for your coalition and employer members. On April 28, 2015, H.R. 2050 was introduced and assigned to a congressional committee. The purpose of this bill is to amend the Internal Revenue Code of 1986 to repeal the excise tax (Cadillac tax) on high cost employer sponsored health care coverage. Thank you to North Carolina Business Group on Health for offering the attached letter as a template that coalitions can share with employers.

Please click here to download the North Carolina Business Group on Health'
s letter to the NC Republican Representatives.

Please click here to download the NP's Can Lobby document.

KING V. BURWELL RESOURCES

On June 25, the Supreme Court ruled (6-3) that the federal health insurance subsidies shall remain available to individuals in the 37 states usingwww.healthcare.gov. This decision means that the major coverage provisions of the Affordable Care Act will proceed as planned. NBCH will continue work to ensure that implementation of this and other substantive laws reflect the needs of our membership.


As this ruling leads toward a focus on implementation, NBCH is providing this new section on our website to gather the most recent headlines and resources on the topic to offer you additional education.


CommonWealth Fund Blog: Coverage and Financial Security Preserved for Millions of Americans in the Supreme Court Ruling for the Government


Wall Street Journal Blog by Drew Altmann: After King v Burwell Ruling, Health Law Issues Involve Implementation

Modern Healthcare: Guide to King v. Burwell



NBCH PREPARES TO SUBMIT COMMENTS ON EEOC PROPOSED WELLNESS AND INCENTIVE REGULATIONS

The Equal Employment Opportunity Commission released a proposed rule to amend regulations under Title I of the Americans with Disabilities Act, specifically related to employer wellness programs. While NBCH applauds the effort of EEOC to bring clarity to this topic, we have identified areas for improvement. The draft comment letter can be found here, and will be updated with the submitted version by June 15. Additional background information, including slides and recorded presentation, can be found here


NBCH SUBMITS COMMENT LETTER TO THE IRS ON THE UPCOMING EXCISE TAX NOTICE

Recap - May 5, 2015
NBCH Webinar:
The Excise Tax: Latest Guidance and Your Opportunity to Comment

Webinar Slides


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 notice.comments@irscounsel.treas.gov


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.



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