Affordable Care Act and Its Impact on Senior Living: Compliance and Solutions

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Agenda   ACA Timeline

•  Willis Health Care Reform Survey Results   Guidance on Health Care Reform   Strategies for Consideration   Leveraging your ALFA Membership

•  Opportunities for Group Leveraging and Purchasing •  Benefit Administration •  Record Keeping

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ACA: Timeline •  •  •  •  •

SBC Coverage Summary W-2 Cost Reporting PCORI Fee MLR Payouts Women’s Preventive Services •  Internal and External Review

Entire Law Upheld

•  •  •  •  •  •  •  •  •  •  •  •  •

Individual Mandate Employer Mandate – Essential, Affordable State Exchanges – Taxpayer – paid Credits Annual Dollar Limit on EHB Lift 90 Day Wait Maximum Adult Child Grandfather Ends Cafeteria Plans Permitted for Exchange Coverage Pre-ex Ends For All Medicaid Expansion New Tax on Health Insurers Reinsurance Fee Enhanced Wellness Financial Incentives OOPM Limit = HSA Limit •  All State Exchanges Open to <100

2010

2011

2012

2013

2014

2015

2016

•  Delayed Provisions •  Auto Enrollment (> 200) •  Insured Non Discrimination Testing •  •  •  •  •  •  •

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FSA $2,500 Limit 2.3% Medical Device Tax .9% FICA – Med Surtax on High Earners Itemize Medical at 10@ AGI (up from 7.5%) PCORI fee Increase Notice of State Exchanges and Subsidies Elimination of Medicare Part D Tax Deduction

2017

2018

2019

2020

•  “Cadillac Excise Tax”

•  State Exchanges – Potential Expansion to Large Employers

•  Part D “Donut Hole” Phase Out Complete


Willis National Health Care Reform Survey – What We Have Learned   Employers will continue many existing strategies

•  Expansion of Wellness Offering •  Redesign of benefit options and eligibility provisions   Most employers plan to “play” under the “play or pay” mandate

•  Continuation of the “compliance as we go” approach as opposed to adopting a Total Rewards strategy   Employers are concerned with cost, but underestimate the cost of

compliance •  60% of employers say that avoiding cost increases is the most important consideration for their businesses •  Over half of surveyed employers have not determined the cost of Health Care Reform compliance 3


Federal Healthcare Reform Public Exchanges   Federal exchange for 32 states o  Initial open enrollment to start 10/1/13   19 states/DC establish exchanges   7 partnership exchanges   25 states default to federal exchange   Question about tax credits and penalties for coverage on federal exchange

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Guidance on Health Reform   Pay or Play” rules - Large employers must offer affordable health

coverage (meeting MEC rules) to substantially all FTEs   Case study

•  Happy Village – 1000 employees (930 salaried; 70 hourly) •  Health coverage offered only to salaried employees   Issue 1 – Offering coverage to substantially all FTEs

•  •  •  •

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Regulations provide a 5% allowance for offering coverage Happy Village fails the 95% test Penalty is $2,000 for each FTE (less 30) prorated monthly Happy Village penalty is $1,940,000 annually


Guidance on Health Reform   Issue 2 - Determining FTEs

•  Ongoing Employees vs. New Hires ‒  Standard Measurement Period ‒  Stability Period ‒  Administrative Period •  Nuanced rules for ‒  Different categories of employees ‒  Seasonal employees ‒  Mid year employment status changes ‒  Rehires

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Guidance on Health Reform

Managing the Variable Hourly EE Eligibility Requirements Case Study for Ongoing FTE Calculation 1/1/2014

4/1/13

10/1/13

1/1/2015

10/1/14

Transition Year SMP “Lookback Period” 6 months

AP

2014 Stability Period = Calendar Year

SMP “Lookback Period” 12 months

SMP – Standard Measurement Period AP – Administration Period SP – Stability Period

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AP

2015 Stability Period

SMP “Look Back” Period 12 Months


Guidance on Health Reform

Managing the Variable Hour EE Eligibility Requirements – New Hires

1/1/2014

1/1/2015

1/1/2016

10/1/14

10/1/15 2015 Stability Period = Calendar Year

6/1/14

6/1/15

New Hire “Initial Lookback Period” 12 months

Initial Stability Period

SMP “Lookback Period” 12 months

10/1/14

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2016 Stability Period

AP

9/30/15

2016 Stability Period SMP “Look Back” Period 12 Months


Federal Healthcare Reform Public Exchanges

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Guidance on Health Reform   Pay or Play” rules - Large employers must offer affordable health

coverage (meeting MEC rules) to substantially all FTEs   Issue 3 - Affordable health coverage – cost of single coverage is not

more than 9.5% of household income •  Safe harbor rule – single coverage cost not more than 9.5% of employee pay (Box 1 of W-2) •  Penalty - $3,000 for each employee who obtains coverage and premium assistance through a state exchange (prorated monthly)

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Strategies for Consideration Option 1

Option 2

Option 3

Maintain Status Quo

Mostly Play

Compliant Creative Strategy

Meet all PPACA requirements   Continue employer sponsored healthcare model   Plan remains affordable for all employees   Tweak/Adjust existing coverage, contributions, reporting, etc. 

Meet some PPACA requirements   Allow low wage workers to qualify for government subsidies/ Medicaid   Pay $3,000 penalty for those ee’s who leave plan and receive subsidy   Increase cost sharing for dependents, and/or eliminating spouses coverage 

Meet all PPACA requirements   Offer minimum possible coverage that would avoid penalties   60% plan design with no coverage for spouses   Contributions set at 9.5% of wages for selfonly coverage, and 100% cost for child coverage 

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Strategies for Consideration: Example of a “Redesign”   Offer a multi plan offering to meet minimum compliance guidelines while

offering affordable options to all employees Tradition Plan(s)

Minimum Compliance Plan

Alternative Reimbursement Plans

Plan A

Plan B

Plan C

Current Medical Option(s)

“Bronze Option” for ACA Compliance

Fixed Indemnity, Hospital Confinement, Critical Illness, and Accident

Estimate: $850 PEPM

Estimate: $400 PEPM

Estimate: $250 PEPM

Cost may vary based on plan designs offered

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Strategies for Consideration: “Defined Contribution”   Provide all employees

equal amount to spend on healthcare and ancillary benefits with a wide range of choices and allow employees to select coverage based on their risk preferences

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ACA Total Solution Delivery CONSULTING & DESIGN

TECHNOLOGY & SERVICES

Account Management (Define)

Traditional Administration (Define)

•  Strategic Planning •  Compliance Management •  Program Implementation

•  Highly Flexible Implementation •  Employee Benefit Portal •  Call Center

Plan Design Management (Design)

Benefit Exchanges (Design)

•  Health & Welfare Plan Design •  Financial Budgeting/Underwriting •  Employee Communication

•  Total Benefit Marketplace •  Supports Legacy Plans •  Supports Defined Contribution

Vendor Management (Deploy)

Regulatory Compliance (Deploy)

•  Contract Management/Renewal •  Performance Standards and Audits •  Implementation

•  Compliance Testing Process •  Integration with HRIS •  Record Keeping

Integrated Benefit Administrator and ACA Compliance Technology 14


ALFA Solution - Group Leveraging Strategy Preferred Pricing from Carriers -

Solution Spectrum +

+

Cost of Benefit Administration

-

Benefit Administration Only

Maintain Existing “Core Benefits” and offer Alternative Reimbursement Plans

Maintain Existing “Medical Benefits” and offer Ancillary Plans

Adopt Full ALFA Group Purchasing Strategy

Defined Contribution Marketplace

•  Employee Benefit Portal •  Online Enrollment •  Call Center •  Improved Employee Communication •  Eligibility Management •  ACA Record Keeping •  Reduce HR Team workload

•  Benefit Administration •  Continue current Medical, Dental, Life and Disability carriers •  Offer Alternative Reimbursement Plans o  Fixed Indemnity o  Hospital Confinement o  Critical Illness o  Accident

•  Benefit Administration •  Continue current Medical and Dental carriers •  Offer Ancillary Plans o  Life o  Disability o  Fixed Indemnity o  Hospital Confinement o  Critical Illness o  Accident

•  Benefit Administration •  Offer Choice of Plans o  Medical o  Dental o  Life o  Disability o  Fixed Indemnity o  Hospital Confinement o  Critical Illness o  Accident

•  Benefit Administration •  Provide all employees equal amount to spend on healthcare and ancillary benefits with a wide range of choices and allow employees to select coverage based on their risk preferences

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ALFA Solution – Preferred Pricing Carriers Medical

Life and Disability

Dental

Voluntary

Vision

Stop Loss (Self Insured Medical)

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Questions?

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