As Fall arrives, employers and administrators of health plans know that a new season of open enrollment is upon us. New companies, and even experienced benefits departments that may have fallen into an annual routine over the years, could always use a refresher on how to prepare for this important time for both employees and owners. Below are six helpful tips to consider during this important time of year.
- Mobile Apps. If you haven’t already, look into whether your health insurance provider or third party administrator has a ready mobile app that your plan participants can download and use at their convenience. Some major carriers have created apps to help participants view their coverage and benefits, locate network providers, access their ID cards, contact the insurance provider, and utilize other plan-specific services. Alerting participants to the existence of these apps during open enrollment can help foster more independence by employees throughout the plan year.
- Summary of Benefits and Coverage. For your medical plan, make sure that plan participants receive—and review!—a copy of the Summary of Benefits and Coverage (SBC) for the upcoming plan or policy year. Directing your plan participants to this resource may help cut down on the number of questions you or your plan administrator may receive during open enrollment (including where to find more information about the plan). The SBC, mandated by the Affordable Care Act, is a uniform, 5-page summary for participants that explains what services a health plan covers, and the benefits levels (e.g., copays or coinsurance) the plan provides for those services. The SBC is generally distributed to participants no later than 30 days prior to the start of the new plan or policy year.
- FSAs and HSAs. There are some important differences between a flexible spending arrangement (FSA) and a Health Savings Account (HSA), including the eligibility requirements for an HSA, and the “use-it-or-lose-it” rule for FSAs. Both accounts are available to employees on a pretax basis. But employers may need to brush up on the differences between any FSA and HSA that they offer.
- Tout Your Supplemental Benefits. If you offer supplemental voluntary benefits, such as group life insurance, short-term or long-term disability, ADD or critical illness coverage, be sure to highlight these lesser-emphasized benefits to employees in your open enrollment materials, so they appreciate that you are offering a comprehensive and competitive benefits package. If you provide an employer contribution to employees’ FSAs or HSAs, highlight that, too. The same goes for any 401(k) match.
- Health Insurance Marketplace. Only in existence since 2014, the Health Insurance Marketplace for private individual coverage created by the Affordable Care Act (also known as the “Exchanges”), has its own open enrollment period. For 2019 coverage in the Marketplace, open enrollment runs from November 1, 2018, to December 15, 2018. Most employees of companies offering ACA-compliant group health coverage will not have good reasons to shop for coverage in the Marketplace, as these employees will be ineligible for premium assistance in the Marketplace, and their group health coverage may also provide equal or better plan benefits. Nonetheless, it will serve plan administrators well to know of the Marketplace option and upcoming enrollment dates to generally respond to inquiries from employees and plan participants. More information regarding Marketplace enrollment can be found on Healthcare.gov.
- Medicare Open Enrollment. Confusingly, Medicare runs a slightly different open enrollment period than the Marketplace. Medicare open enrollment runs from October 15, 2018, to December 7, 2018. As a reminder, Medicare is available to individuals age 65 and older, and those with disabilities or End-Stage Renal Disease. Group health plans always need to know if any of their plan participants or dependents (including spouses) are enrolled in Medicare for the purpose of coordinating benefits with Medicare.
There are many variations of the Medicare coordination rules that are beyond the scope of this post. However, an important one for employers is that when an age 65 Medicare beneficiary also has group health coverage through that beneficiary or their spouse’s current employment with an employer of 20 or more employees, the group health plan is considered primary and by law must pay its benefits first. A common pitfall in this circumstance occurs when an employee or spouse mistakenly submits their Medicare card to a provider, which then bills Medicare for services that an employer’s group health plan should pay first, only to have Medicare come back to the group health plan months or even years later demanding reimbursement of sometimes significant claims payments. For this reason, employers should ensure that a process is in place with their plan administrators to keep track of which employees and dependents are also enrolled in Medicare.