The Patient-Centered Outcomes Research Trust Fund fee is a fee on issuers of health insurance policies and plan sponsors of self-insured health plans that helps to fund the Patient-Centered Outcomes Research Institute (PCORI), which was established by the Affordable Care Act (ACA). The institute assists, through research, patients, clinicians, purchasers and policy-makers, in making health decisions by advancing the quality of evidence-based medicine. The institute compiles and distributes comparative clinical effectiveness research findings. Under the ACA, all medical plans are responsible for paying the Patient-Centered Outcomes Research fee to the IRS, based on the number of plan participants. If the plan is fully-insured, the insurance carrier pays the fee on behalf of the policyholder. If the plan is self-insured, the employer/plan sponsor must file the Form 720 for the second quarter and pay the fee to the IRS directly.
The IRS recently published its PCOR fee for policy and plan years ending: January through September 2018 the applicable dollar amount is $2.39, which is multiplied by the number of covered lives determined for the appropriate period. For policy and plan years ending October through December 2018, the applicable dollar amount is $2.45.
All self-insured medical plans, including health FSAs and HRAs must pay the fee unless they are considered an excepted-benefit:
- A health FSA is an excepted-benefit as long as the employer does not contribute more than $500/year to the accounts and offers another medical plan with non-excepted benefits.
- An HRA is an excepted-benefit if it only reimburses for excepted-benefits (e.g., limited-scope dental and vision expenses or long-term care coverage) and is not integrated with the group medical plan.
The PCORI fee is calculated off the average number of lives covered during the policy year. That means that all parties enrolled will have to be accounted for such as dependents, spouses, retirees, and COBRA beneficiaries. For HRA and health FSA plans, just count each participating employee as a covered life.
Payment of the PCOR fee for the calendar 2018 plan year — the last year the fee applies — will be due by July 31, 2019 (payments may extend into 2020 for non-calendar-year plans).
Clients who have elected to have Diversified Group assist with the PCOR fee calculation can expect an email in June 2019, which will include a copy of the completed Form 720 and a PCOR calculation worksheet with supporting documentation. Clients will need to file the Form 720 by July 31, 2019.
The Health Insurance Responsibility Disclosure (HIRD) form is a new state reporting requirement in Massachusetts beginning in 2018. This form differs from the original HIRD form that was passed into law in 2006 and repealed in 2014. The 2018 form is administered by MassHealth and the Department of Revenue (DOR) through the MassTaxConnect (MTC) web portal. The HIRD form is intended to assist MassHealth in identifying its members with access to employer sponsored health insurance who may be eligible for the MassHealth Premium Assistance Program. The HIRD form is required annually beginning in 2018. The reporting period opens on November 1 and must be completed by November 30 of the filing year.
Any employers with six or more employees in Massachusetts in any month during the past 12 months preceding the due date of the form (November 30th of the reporting year) are required to annually submit a HIRD form. An individual is considered to be an employee if they were included on the employer’s quarterly wage report to the Department of Unemployment Assistance (DUA) during the past 12 months. This includes all employment categories, full-time and part-time.
The HIRD form is reported through MassTaxConnect (MTC) web portal (https://mtc.dor.state.ma.us/mtc/_/#1). The MTC is where employer-taxpayers register to file returns, forms and make tax payments. To file your HIRD form, login to your MTC withholding account and select the “file health insurance responsibility disclosure” hyperlink. If you do not have a MTC account or you forgot your password or username, follow the prompts on the site or call the DOR at 614-466-3940.
INFORMATION REQUIRED FOR HIRD REPORTING
The HIRD Form will collect information about the employer’s insurance offerings, including:
- Plan Information – plan year, renewal date.
- Summary of benefits for all available health plans – information regarding in and out of network deductibles and out-of-pocket maximums can be found on the plan’s summary of benefits and coverage.
- Eligibility criteria for insurance offerings – minimum probationary periods and hours worked per week to be eligible for coverage. Employment based categories, such as full-time, part-time, hourly, salaried.
- Total monthly premiums of all available health plans
- Employer and employee shares of monthly premiums – information on employer and employee monthly contributions toward the cost of medical. Employer cost of coverage is your COBRA rate less 2% and less the employee contribution.
Due to the nature of the filing online, employers with employees in Massachusetts will need to complete this reporting themselves. However, Diversified Group may be able to assist you in the gathering of the required information. Please contact us by November 15th if you need assistance with accumulating data.
Mass.gov has compiled a list of frequently asked questions regarding the HIRD form here.
Section 1332 of the Affordable Care Act (ACA) permits a state to apply for a State Innovation Waiver to pursue innovative strategies for providing their residents with access to high quality, affordable health insurance while retaining the basic protections of the ACA. Recently several states have applied for waivers and have been approved. Among these is the State of Maine, which sought to reestablish the Maine Guaranteed Access Reinsurance Association – MGARA (originally established in 2012 but later suspended in light of the ACA’s transitional reinsurance program which expired in 2016). Maine’s Section 1332 waiver to reestablish MGARA was approved by the Department of Health and Human Services earlier this year. MGARA is a state instituted reinsurance program that automatically cedes high-risk enrollees with one of eight conditions (including various types of cancer, congestive heart failure, HIV and rheumatoid arthritis) and voluntary cedes other high-risk enrollees to the pool in an attempt to help stabilize individual medical premiums by about 9 percent each year beginning in 2019. The program is slated to initially run from January, 2019 through December, 2023. The Governor’s Office pushed to get the program up and running by January, 2019 in an attempt to substantially lower premiums in the individual market.
One of the funding sources supporting MGARA’s operations is a quarterly assessment due from each insured and self-insured plan that writes or otherwise provides medical insurance in Maine (other than federal or state government plans) beginning in 2019 at $4.00 per month for each covered person enrolled under each such policy or plan. Only federal and state employees are exempt from the assessment. The 2019 Quarterly Assessment will apply to policies and plans initiated or renewed on or after January 1, 2019, with the first assessment due on May 15, 2019, and 45 days from the end of each calendar quarter thereafter. Self-funded plans using a Third Party Administrator (TPA) will be assessed and reported through their TPA similar to other state assessments.
Diversified Group will collect and report the MGARA on behalf of our self-insured clients who have members residing in Maine.
Diversified Group is celebrating the season of giving and will be holding a food drive for our local food bank, the Food Bank of Marlborough, Connecticut. Please consider donating this holiday season as this is the time of year when food banks are in the most need. Donations will be collected until December 13th.
The food bank provides hams for Christmas dinners, so anything that you can think of that would accompany a ham dinner, whether side dishes or supplies, would be helpful. Below is a list of some suggested items:
Pie Crusts (Boxed)
Any Canned Goods
Spray Shortening (Pam)
Salt & Pepper
Rice Packages (Flavor or Regular)
*Please No Paper Goods
Please drop off all donations to our offices at 369 North Main Street in Marlborough, Connecticut. And if you would like more information on the Food Bank, please visit http://www.foodbankofmarlborough.org/.
Diversified Group has been awarded a 2018 Top Workplaces honor by The Hartford Courant! The list is based solely on employee feedback gathered through a third-party survey administered by research partner Energage, LLC (formerly WorkplaceDynamics), a leading provider of technology-based employee engagement tools. The anonymous survey measures several aspects of workplace culture, including alignment, execution and connection, just to name a few.
“Top Workplaces is more than just a recognition,” said Doug Claffey, CEO of Energage. “Our research shows organizations that earn the award attract better talent, experience lower turnover and are better equipped to deliver bottom-line results. Their leaders prioritize and carefully craft a healthy workplace culture that supports employee engagement.”
“We couldn’t be more thrilled to be receiving this honor for the second year in a row,” stated Brooks Goodison, President of Diversified Group. “Every day our employees work closely with our clients and their plan members doing everything they can to help people make better healthcare decisions. To be able to foster an environment that these hard-working people are proud to be a part of is so rewarding.”
“Becoming a Top Workplace isn’t something organizations can buy,” Claffey said. “It’s an achievement organizations have worked for and a distinction that gives them a competitive advantage. It’s a big deal.”
The Medicare Prescription Drug Improvement and Modernization Act of 2003 implemented prescription drug coverage under Medicare (Medicare D), requiring all employers that offer prescription drug benefits to provide an annual notice of Medicare open enrollment. The notice must go to all Medicare eligible plan participants and qualified beneficiaries before October 15th each year. The notice requirement applies to all employers offering prescription drug benefits regardless of size, whether fully-insured or self-funded, or regardless of ACA grandfathered status. Notification must go to all Medicare eligible plan participants, including active employees and their dependents, retirees and COBRA participants. For most employers, it is easier to issue the notice to all participants as a blanket notice than to identify Medicare eligible employees.
The notice requires that the plan sponsor first determine if their plan offers creditable coverage (meaning it is on average at least as comprehensive as Medicare D coverage), or non-creditable. The Centers for Medicare and Medicaid Services (CMS) provides a simple process to determine whether prescription drug coverage is creditable or not. Once that determination is made, CMS provides model notices to send to participants in both English and Spanish. Notices may be sent separately, included as part of open enrollment or other benefit related materials, or electronically as long as the DOL’s rules on electronic delivery are followed.
Additionally, all plan sponsors are required to notify CMS within 60 days of the start of each plan year as to whether or not their prescription drug plan is creditable or not creditable. This notification is done online at CMS here.
For Diversified Group clients who have elected to have Diversified Group handle your Medicare D notices, DG will determine if the plan is considered creditable or not and will then send the notice either to the client or directly to the plan participant depending upon which service was elected.
May is National Employee Health & Fitness Month! Diversified Group’s wellness consulting and services company, Corporate Fitness & Health (CF&H), celebrates employee health and fitness all year long. But, they want to encourage all organizations to use this month to show their employees how much they care about their well-being. With chronic illnesses (and the expensive medical claims that go with them) on the rise, employers have started to take it upon themselves to help encourage employees to focus on their health. However, employee wellness programs are not just about saving money on medical claims. It’s about taking care of the people you rely on for your business to be successful.
So, What Can You Do to Celebrate?
Here is a list of things you can do to encourage employee wellness at your organization:
- Provide employees with a company-wide walking break. Even just 20 minutes of walking can do wonders for the heart and the mind.
- Provide a healthy breakfast or luncheon. Many companies are quick to bring in pizza for their employee luncheons, but if you have been trying to educate employees on good nutrition, providing healthy sandwich and salad options sends a stronger message that you really believe in it. More and more places are now offering healthier catering options such as Subway, Panera, Cosi and B.GOOD (locations vary).
- Provide an onsite seminar or display. Give your employees a chance to learn something new about their health or an opportunity to practice some healthy behaviors. Corporate Fitness & Health can offer a variety of educational opportunities with topics ranging from exercise to stress to nutrition.
- Host an onsite blood pressure clinic. A simple blood pressure check takes less than 2 minutes, but it can potentially save a person’s life if they haven’t been to see their doctor in a few years.
- Kick off a wellness challenge. Sometimes a little competition goes a long way when it comes to motivating people to focus on their health. Challenges can cover a variety of health habits, such as walking or other exercise, fruit and veggie consumption, weight loss, hydration challenges and more.
And, don’t forget that May is also Mental Health Awareness month. So, it is also a great time to try offering meditation breaks. CF&H has skilled staff members who can lead guided meditation sessions and teach valuable breath-work techniques to help reduce stress.