2021 Cost-Sharing Limits; HDHP Out-of-Pocket Limits and Deductibles

A non-grandfathered group health plan’s in-network out-of-pocket maximum for essential health benefits (EHBs) for the 2021 plan year cannot exceed $8,550 for self-only coverage and $17,100 for other than self-only coverage. 1 This is an increase of approximately 4.9% percent from 2020. The in-network out-of-pocket maximum applies to all individuals, regardless of whether an individual has a self-only plan or other-than-single coverage.

Self-funded group health plans are not required to cover EHBs. But, if they do, they cannot impose lifetime or annual dollar limits on those benefits.

For high-deductible health plans (HDHPs) for the 2021 plan year, the out-of-pocket limit will be $7,000 for self-only coverage and $14,000 for other-than self-only coverage.2 The minimum deductible is not changing from 2020, remaining $1,400 for self-only coverage and $2,800 for other than self-only coverage.

1 Notice of Benefit and Payment Parameters for 2021, Final Rule from the U.S. Department of Health and Human Services, May 14, 2020

2 Rev. Proc. 2020-32 from the IRS, April 30, 2020

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Filed under Cost sharing, Healthcare reform, High-deductible health plan

Preventive Care Recommendations

The following U.S. Preventive Services Task Force (USPSTF) recommendations have been added to the preventive healthcare services that non-grandfathered health benefit plans must cover at 100% when provided by a network provider. Star Marketing & Administration, Inc., will implement the recommendations on the dates provided below.

  • Effective Sept. 1, 2020, in addition to risk reducing medications such as tamoxifen and raloxifene, the USPSTF recommends the prescription of aromatase inhibitors to women who are at increased risk for breast cancer and at low risk for adverse medication effects
  • Effective Dec. 1, 2020, anxiety screening for adult women and adolescent girls, including pregnant and postpartum women.
  • Effective Dec. 1, 2020, the recommendation for Hepatitis C screening for adults born between 1945 and 1965 and adults who are at high risk for infection, has been changed to screening for Hepatitis C in adolescents and adults aged 18 to 79.

The Affordable Care Act prohibits imposing member cost sharing, such as copayments, deductibles or coinsurance, when these services are provided by a network doctor or hospital. However, plans may impose cost sharing if the services are provided out of network.

For more on preventive care, follow this link.

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HHS Announces Changes in Implementing Anti-Discrimination Rule

The U.S. Department of Health and Human Services (HHS) has changed how it implements Section 1557 of the Affordable Care Act (ACA). The federal final rule applies to health plans, insurers, hospitals, doctors, and other medical providers that receive HHS funding.

Effective Aug. 18, 2020, changes to the 2016 version of the Section 1557 rule include:

  • Elimination of the requirement to issue anti-discrimination notices and taglines on all significant documents
  • Elimination of the requirement to designate a responsible employee and grievance procedures

Section 1557 prohibits discrimination on the basis of race, color, national origin, sex, age, or disability in certain health programs or activities.

The new rule eliminates a 2016 mandate that required covered entities to distribute non-discrimination notices and “taglines” translation notices in at least 15 languages in all “significant communications” to patients and customers. The regulations of the underlying statutes referred to in Section 1557 (Title VI, Section 504, Title IX, and the Age Act) have long mandated that covered entities provide a notice of nondiscrimination. This final rule maintains that requirement.

Moreover, it continues to require covered entities to provide taglines whenever such taglines are necessary to ensure meaningful access by LEP individuals to a covered program or activity. It removes only the requirement that all significant communications contain taglines.

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Filed under Healthcare reform, Non-Discrimination, Section 1557

Form 5500 Relief Deadline Approaching

The IRS issued Notice 2020-23 which addresses Form 5500, Annual Return/Report of Employee Benefit Plan filings due between April 1, 2020, through July 15, 2020. This relief does not include calendar year-end 2019 Form 5500 filings due July 31, 2020.

The relief is for Form 5500 filings that were either due to be filed originally or through an extension. The relief due date for filings has been extended to July 15, 2020. The extension automatically applies to Form 5500 filings for plan years that ended in September, October or November 2019 because the regular due dates for these filings would have been, respectively, April 30, June 1 (because May 31 was a Sunday), and June 30, 2020; these filings are now due July 15, 2020.

Taxpayers do not need to file official extension forms or send other documents requesting the relief. However, additional filing extensions beyond July 15 must be requested using the appropriate extension form by July 15, but the extension may not go beyond the original or regulatory extension date.

Notice 2020-23 states that Specified Time Sensitive Actions are covered and refers taxpayers to Rev. Proc. 2018-58, which explicitly addresses Form 5500.

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IRS Announces PCORI Fee and Transitional Relief

The IRS has announced that the Patient Centered Outcomes Research Institute (PCORI) Fee is $2.54 per average number of covered lives for plan years ending Oct. 1, 2019, through Sept. 30, 2020.

  • For plan years ending Oct. 1, 2019, through Dec. 31, 2019, fees are due July 31, 2020.
  • For plan years ending Jan. 1, 2020, through Sept. 30, 2020, fees are due July 31, 2021.

The previous fee was $2.45 per average number of covered lives for health benefit plans ending Jan. 1, 2019, through Sept. 30, 2019. These fees are due July 31, 2020.

The PCORI fee expired on Sept. 30, 2019, but was then extended through Sept. 30, 2029.

Transitional Relief

Plan sponsors may continue to use one of the following three methods to calculate the average number of covered lives for purposes of the fee: the actual count method, the snapshot method and the Form 5500 method.

In addition, for plan years ending Oct. 1, 2019, through Sept. 30, 2020, plan sponsors may use any reasonable method for calculating the average number of covered lives and that method must be applied consistently for the duration of the plan year.

The institute, a nonprofit organization, uses the fee to fund research to compare different medical treatments and interventions to determine what treatments are most effective with the help of clinicians, purchasers, policymakers and patients. The institute will compile and distribute comparative clinical effectiveness research findings.

For more information, follow this link.

 

 

 

 

 

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Employers Scheduled to Receive PCORI Fee Mailing

This week, employers with a self-funded health benefit plan design that are required to pay the Patient-Centered Outcomes Research Institute (PCORI) fee will be sent a letter via mail providing their group’s “average covered lives” during the plan year ending in 2019 (using the Snapshot Count method).

As a courtesy, the Broker of Record will receive a duplicate copy of the letter sent to their group(s). The letter will also be posted to the Document Center at TrustmarkSB.com for the employer, the Broker of Record and the broker’s managing general agent to view.

The Affordable Care Act and associated regulations require health insurance issuers and plan sponsors of self-funded group health plans to file and pay an annual PCORI fee.

Plan sponsors of self-funded health plan years ending in 2019 are required to pay the fee to the IRS and file Form 720 by July 31, 2020.

To learn more about the PCORI Fee, follow this link

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Cadillac Tax Repealed

The Cadillac tax, which would have imposed a 40 percent excise tax on employer-sponsored health benefits whose value exceeds certain thresholds beginning in 2022, has been repealed.

The 40 percent excise tax would have been imposed on plan administrators and insurers when the cost of employer-sponsored health coverage exceeds $11,200 for single coverage and $30,150 for family coverage for plans beginning in 2022.

The tax was delayed twice: in 2015 and 2018. It was repealed as part of the fiscal year 2020 appropriations legislation passed in 2019.

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Proposed Rule on Price and Cost Sharing

Required disclosures to participants and beneficiaries

The federal government is proposing a rule that would require self-funded, non-grandfathered employer-based group health plans and health insurers offering non-grandfathered group and individual health coverage to disclose cost-sharing information to participants, beneficiaries and enrollees upon request.

The Transparency in Coverage proposed rule was released by the U.S. Departments of Health and Human Services, Labor and the Treasury in late November 2019. The rules would be effective one year after the effective date of the final rule.

Continue reading here.

 

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Federal Government Releases Hospital Price Transparency Rule

A new federal rule requires hospitals operating in the U.S. to publish their prices for items and services on their websites, effective Jan. 1, 2021. According to the rule, these requirements will promote price transparency in healthcare and public access to hospital standard charges. The rule requires each hospital to establish and make public annually a list of its standard charges for items and services by location. Continue reading

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PCORI Fee Extended for 10 Years

The Patient-Centered Outcomes Research Institute (PCORI) fee has been extended 10 years through 2029.

PCORI will continue to use these fees to fund research to compare different medical treatments and interventions to determine what treatments are most effective with the help of clinicians, purchasers, policymakers and patients. The non-profit organization’s mission is to help doctors and patients make evidence-based healthcare decisions.

Before the extension, the fee expired with policy or plan years ending Sept. 30, 2019, (with payment due July 31, 2020). Insurers of fully insured plans and sponsors of self-funded plans ending between Oct. 1, 2018, and Sept. 30, 2019, were assessed a fee of $2.45 per average number of covered lives.

We will provide more information about the fee as it becomes available.

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