Large group health care reform

• Employer Shared Responsibility

  

• Taxes and Fees

  

• Enrollment and Renewals

  

FAQs

• Is our Group plan Grandfathered?
  Group health plans and health insurance plans that were in place on March 23, 2010, when the PPACA was enacted, are called grandfathered plans and are exempt from some elements of the law. However, to maintain grandfathered status, a plan cannot reduce or eliminate benefits, increase employee cost-sharing above certain thresholds, or reduce the employer share of the premium payment. Once a plan loses its grandfathered status, it must comply with all applicable requirements of the law. It is the employer group’s responsibility to determine if the plan is grandfathered or not.
• For large groups (51+), will the taxes and fees be embedded in the renewal rate, or charged as separate line items?
  As shown in the table below, for large group grandfathered and non-grandfathered plans, only the PCORI Fee will be embedded in rates. The Health Insurance Premium Tax, Transitional Reinsurance Program and HICAA Tax will be charged as separate line items.

  Plan Type	Embedded	Separate Line Item	Not Charged
  Grandfathered and Non-Grandfathered Plans (Effective January 1, 2014	PCORI Fee*	Reinsurance Fee** >Premium Tax** HICAA Tax*	Exchange User Fee

  *PCORI Fee became effective in 2012
  
  **Premium Tax, Reinsurance Fee and HICAA Tax embedded by request only; otherwise, they will default to separate line items
• Since the PCORI Fee is embedded, does HAP file the form 720 (Quarterly Federal Excise Tax Return), or does the employer need to file it? If HAP files the form, can we get a copy of the filing for our group?
  HAP will file form 720 for all fully-insured members enrolled with HAP and Alliance. This filing will not be broken down by employer group, thus we are not able to provide a copy of the filing at the group level.
• How did HAP calculate the Health Insurance Premium Tax percentage for 2014 for HMO groups?
  The final premium tax for HMO accounts for 2014 is 1.15 percent, which equates to a per member per month (PMPM) of approximately $4.46 on average. This was calculated based on HAP’s estimated fee of $14.7 million (50 percent of full fee due to not-for-profit status), which then is broken out between our Medicare and Commercial book of business. For Commercial, based on our projected 2014 premium platform and associated insured member months, we calculate a needed fee of $10.9 million, which results in a charge of 1.15 percent, or $4.46 PMPM.
• How did HAP calculate the Health Insurance Premium Tax percentage for 2014 for Alliance groups?
  The final premium tax for Alliance accounts for 2014 is 1.55 percent, which equates to a per member per month (PMPM) of approximately $3.59 on average. This was calculated based on the Alliance estimated fee of $2.7 million, which then is broken out between our Medicare and Commercial book of business. For Commercial, based on our projected 2014 premium platform and associated insured member months, we calculate a needed fee of $2.1 million, which results in a charge of 1.55 percent, or $3.59 PMPM.
• Are group Medicare Advantage plans subject to PPACA taxes and fees?
  Medicare Advantage (MA) plans are not subject to all PPACA taxes. MA plans are subject to the Premium Fee. MA plans are not subject to: Reinsurance, PCORI, Exchange User or Risk Adjustment Fees.
• Are large groups (51+) subject to Risk Adjustment and Exchange User Fees?
  No, these fees apply to small groups and individuals only.
• Will the Premium Tax, Reinsurance Fee and HICAA Tax be shown as one combined line item or multiple line items on the invoice?
  HAP has not yet determined how these fees will be shown on the invoice.