Q- Are Vision Plans subject to COBRA continuation coverage requirements?
BAS can automatically distribute information to all employees with email addresses in MyEnroll. Open enrollment and other communications sent electronically can be an efficient and timely way to communicate with employees. BAS can automatically distribute information directly to your employees' email accounts and save the communication as a PDF in each employee's MyEnroll.com record. Emails can be sent to all email addresses on record for each employee.
While most communication with participants occurs through BAS' secure email system, many employers engage BAS to communicate with employees through direct mailings. Like BAS' email communication procedures, BAS has processes in place to ensure a smooth mailing distribution while maintaining the privacy and integrity of employer information.
Group health plans must report to the Centers for Medicare and Medicaid Services (CMS) Social Security Numbers or Medicare Insurance Claim Numbers for employees and their covered family members who might have Medicare coverage in addition to coverage under the employer group health plan. Many employers with fully-insured health plans have been contacted by their insurers to collect SSNs and HICNs for their participating employees. Self-funded plans may have their own reporting requirements. The reporting, required under Section 111 of the Medicare, Medicaid and SCHIP Extension Act of 2007, helps CMS identify Medicare-covered individuals with group health plan coverage that should pay claims primary to Medicare.
This week the Supreme Court heard 6 hours of oral argument on the legality of health care reform. The last time the Supreme Court entertained that length of oral arguments was when it addressed the constitutionality of Miranda rights in the 1960s. 26 states have challenged the constitutionality of the Affordable Care Act, and over 170 briefs were submitted to support or oppose the law.
With March Madness upon us, consider answers to some of your college basketball benefits questions.
BAS is transmitting health plan data in HIPAA 5010 format to providers who will accept the transmission feeds with the updated data requirements. HIPAA 5010 requires health plans and providers to use new standards to electronically conduct certain health care transactions, including claims, remittance and eligibility processing. The HIPAA 5010 transaction standards are intended to increase uniformity among health plans, enhance security, and streamline claim and reimbursement transactions. BAS has been aggressive in driving the conversion to the new, secure format and was frequently one of the first file carriers successfully implementing the conversion. During the conversion process, BAS completed extensive internal testing and external testing with the carriers to ensure there was no participant disruption.
Employers with July 1 plan years are quickly approaching their annual open enrollment periods. With BAS’ MyEnroll system, open enrollment no longer has to be a dreaded, time consuming project.
BAS' open enrollment process, through MyEnroll.com, generally includes the following steps:
- Your dedicated BAS Account Manger will reach out to you (and your broker, if applicable), approximately 90 days before the start of the open enrollment period. BAS will provide a current employee census, rate collection form and payroll worksheet.
- Depending on your needs, BAS will schedule a call or meeting to develop a timeline of tasks to be completed during the open enrollment process. The timeline will address programming, eligibility rules and employee communications.
- BAS will suggest a review of email addresses in MyEnroll to ensure accurate delivery of open enrollment materials.
- If your upcoming plan year includes changes or additions to benefit carrier(s), BAS will work directly with the carrier to ensure seamless file transmissions.
- Approximately 60 days before the start of open enrollment, BAS will work with you to enter plan rates, eligibility rules and payroll schedules into MyEnroll.com. All entries are subject to BAS’ quality control processes. BAS will provide a report indicating what is reflected in MyEnroll.
- BAS will create a customized MyEnroll Enrollment Wizard for your employees to use to complete online enrollment. If online enrollment is not implemented, BAS will provide appropriate paper enrollment forms.
- For employers who use COBRA Control Services (CCS) for COBRA administration, BAS will work directly with CCS to update rates and send open enrollment materials to employees on COBRA coverage.
Group health plans subject to ERISA must extend health coverage to the children of a parent-employee who is divorced, separated, or never married when required by a properly-issued court order. All ERISA plans must have procedures in place for determining if such an order is a qualified medical child support order (QMCSO) and must be followed. These procedures must be distributed upon receipt of an order and upon request. Additionally, a state child support enforcement agency may obtain employer-provided health coverage for a child by issuing a National Medical Support Notice that the health plan determines to be qualified.
The Affordable Care Act is intended to both expand access to health care and make existing health care plans more useful for consumers. One of the enhancements to health plans under health care reform is the elimination of dollar limit restrictions. Beginning 2014, non-grandfathered health plans are prohibited from placing lifetime dollar limits on essential health benefits and are restricted from placing annual dollar limits on health benefits. Annual dollar limits may be phased out before 2014, when they must be eliminated.
Q- I am traveling to Ireland to kiss the Blarney Stone and celebrate St. Patrick's Day. I plan to purchase headache relief medicine to take with me. May I submit the cost of the medicine to my health care flexible spending account for reimbursement?
In keeping with its efforts to protect client data, BAS’ email system will not accept an unencrypted email that contains a formatted social security number in either the email’s subject, body or attachments.
Unencrypted emails sent by administrators or employees to email addresses @ BASusa.com, myenroll.com, or cobracontrol.com (including client-vanity email addresses provided by BAS e.g., clientname@BASusa.com) that contain a formatted social security number will be blocked. A message will be returned to the sender indicating that BAS cannot accept the email.
MyEnroll.com provides COBRA administrators 24/7 access to COBRA correspondence sent to employees, former employees and COBRA beneficiaries. All COBRA correspondence is organized in one central location and provides employers an easily accessible avenue for maintaining information for COBRA compliance purposes.
All employers with group health plans in states that provide premium assistance for the purchase of group health coverage under a Children's Health Insurance Program ("CHIP") or Medicaid must provide notice of the assistance to their employees. Virtually all states provide such assistance, so almost all sponsors of group health plans must have processes and procedures in place to deliver the federally required notice.
Health Care Flexible Spending Accounts (Health FSAs) will be subject to a limit on salary reduction contributions beginning January 1, 2013. The Affordable Care Act created a new $2,500 contribution limit on Health FSAs provided under a cafeteria plan. While early chatter seemed to indicate that the contribution limit would be repealed, it now seems like it is here to stay.
Q- An employee pays for health coverage on a pre-tax basis through a Code section 125 cafeteria plan. The employee is enrolled in coverage for herself and her spouse. She wants to drop her spouse from coverage because the spouse has found a less-expensive individual plan. Can the employee drop coverage for her spouse mid-year so the spouse can enroll in the less-expensive plan?
While the Privacy and Security Rules of the Health Insurance Portability and Accountability Act (HIPAA) may have taken a back seat to changes required under health care reform, audits for HIPAA compliance are on the rise. The Health Information Technology for Economic and Clinical Health Act (HITECH) requires the Center for Medicare and Medicaid Services (CMS) to audit group health plans for compliance with HIPAA.
The Affordable Care Act requires non-grandfathered health plans in the individual and small group markets to include an "essential health benefits package" (EHB) beginning 2014. Insured health plans in the large group market become subject to the EHB requirements as qualified health plans offered through an Exchange beginning 2017.
As part of the ongoing effort to be good stewards of our clients' data, BAS has implemented an outgoing email encryption process.
Q- We are an employer located in Pennsylvania. Our employee is covered under a Pennsylvania-specific HMO, but the employee is terminating employment and moving to California. The termination is a COBRA qualifying event. Do we have to offer the individual a COBRA election since his coverage will no longer be useful for him?