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Identify Your Workers’ Needs, Consider Costs before Open Enrollment

It’s almost time for group health insurance open enrollment and your top priority should be to drive participation by helping your employees make informed decisions about their options.

You’ll want to help your staff understand all of their options so they can choose plans that are best for their age, health and life situation.

This is an important exercise to ensure that any of your workers don’t pick a plan that costs them too much in premium if they rarely use their health insurance, or costs them too much in out-of-pocket expenses if they are frequent users of health care.

It’s a balancing act, since each employee has different needs. Here’s our advice for the open enrollment:

Listen to your workforce

Before you make any decisions, you should listen to your employees and better understand their needs and preferences.

With answers and feedback in hand you can create a benefits package that is more appealing to them, which in turn gives you a competitive edge when attracting and retaining workers.

Engage employees and solicit feedback through quarterly employee-benefits round table meetings. Invite employees from different age groups and different departments to participate in these meetings, to ensure you have a good cross-section of your staff represented.

Give advance notice

You can start now with simple reminders for them to start thinking about open enrollment and evaluate their current health plans. Send out memos and place posters in high-traffic areas.

If you start with this in September or October, they can have time to assess their options, particularly if anything has changed in their lives like marital status, new children or health issues.

Costs are paramount

You can work with us to settle on plan arrangements that will be within your and your employees’ budgets, and that comply with the Affordable Care Act’s affordability and minimum value rules.

Employees have a right to understand the costs they’ll be facing in each plan, including:

  • Their share of the premium,
  • Their deductible,
  • Their copays or coinsurance, and
  • Other out-of-pocket expenses.

Typically, the higher the premium on a plan, the lower the employee’s out-of-pocket costs are. The lower the premium on the plan, the higher the deductible and copays.

Get an early start

If your plan year starts Jan. 1, you should hold open enrollment meetings and dispense plan materials in October or November.

This will give your workers time to review all of their options and compare costs and coverages.

Communicate effectively

Your task is to get employees out of cruise control and truly assess all of their options.

This is especially true if you are making changes to cost-sharing, introducing new plans, or offer voluntary benefits, a wellness plan or health savings account or flexible spending account.

You should use a variety of different media to communicate with them. Use video, virtual and live meetings, e-mail communications, text messages and print materials to get through to your employees. Each generation will often have a preferred medium, so using a multi-pronged approach may be most effective.

Get spouses involved

If you also offer insurance to your workers’ families, you should communicate through your employees that their spouses are also invited to join your open enrollment meetings.\

You may also invite them to view any electronic material you may post online, like the aforementioned videos.

If they cannot make a general meeting, you can invite them to come in to meet with your human resources manager if they have questions.

Remind staff of the ACA

You can use open enrollment as a way to remind your workforce of their responsibilities to secure coverage under the ACA.

Let them know that employees that refuse coverage that complies with the ACA from their employer and opt to purchase it on a public exchange, will usually not be eligible for government premium subsidies.

The meeting

Send out meeting notices early to give your employees time to prepare and set aside time.

Try to make the meeting engaging with props, videos, printed materials and more. You may also want to consider recording the session so that staff who can’t make the meeting can watch it, particularly if you have employees that don’t work on-site.

Provide enough time for the main presentation, as well as for questions from your employees.

The takeaway

Open enrollment can be a hectic and stressful time for both the employer and workers. By getting a head start on planning and communications, you will be ahead of the game and your employees won’t feel harried into making a decision. That benefits both them and your organization.


More Insurers Scale Back on Prior Authorizations

Some of the nation’s largest insurers have announced plans to roll back their prior authorization requirements for medical services, and some are doing this in their Medicare Advantage plans as well.

The moves come as states and the Centers for Medicare and Medicaid Services are implementing rules that aim to streamline prior authorizations for Medicare Advantage plans.

Prior authorization — or prior approval — has always been a thorn in the side of patients, often keeping them from accessing care in a timely fashion. The moves by these insurers come after the CMS announced earlier this year that it would require health insurers to automate prior authorization and return decisions more quickly.

These developments are good news for Medicare Advantage enrollees and should improve their health care experience and access to timely care. Many of these changes took effect immediately and some will start in 2024.

While original Medicare, including Part A, rarely requires prior authorization, Medicare Advantage plans, which are often preferred provider organizations and health maintenance organizations, may require it for certain procedures.

Under prior authorization, doctors and other health care providers must obtain advance approval from a health plan to qualify for coverage before they deliver a specific service to the patient. Health insurers have lists of services that require prior approval, in order to control their costs.

Nearly all Medicare Advantage enrollees (99%) are in plans requiring prior authorization. Often, the prior authorization is for more expensive services, such as an MRI or being transferred from a hospital to a skilled nursing facility.

In 2021, 6% — or 2 million Medicare Advantage prior authorization determinations — were denied, according to a report issued by the Kaiser Family Foundation in February 2023.

What insurers are doing

Here are what a few of the nation’s largest health insurance players are doing:

  • Cigna — In August 2023, Cigna announced with immediate effect that it would no longer require prior approvals for nearly 25% of medical services, and it plans to cut another 500 or so codes that require prior authorization for its Medicare Advantage plans before the end of this year.
  • UnitedHealthcare— UnitedHealthcare, starting in Spring 2023 and lasting through the end of the year, aims to eliminate almost 20% of its current prior authorizations. It also plans to eliminate a code for cardiology stress test prior authorization for Medicare Advantage members, eliminating the need for some 316,000 prior authorization requests a year.
  • Aetna — In 2022, The insurer rolled back prior authorization requirements on cataract surgeries, video EEGs and home infusion for some drugs. Aetna said that it had also reduced automated prior authorizations by more than 10% in 2022, with plans to more than double that this year, according to press reports.

States, regulators taking action

Three states — Louisiana, Michigan and Texas — already have “gold card” laws on their books that except from prior authorization rules certain doctors whose requests are routinely approved. This year, another 24 states have introduced similar legislation, according to a report by the Wall Street Journal.

Meanwhile, in April 2023, the Biden administration implemented a final rule designed to ensure people with Medicare Advantage plans get access to the same necessary care — prescriptions, medical tests, equipment and procedures — as they would receive in traditional Medicare.

The new rules, which require that plans automate their prior approval procedures, are slated to take effect in 2024. The final rule also requires that approval of a prior authorization request for a course of treatment must be valid for as long as medically reasonable and necessary to avoid disruptions in care. 

The new rules would also prevent patients from having their medical care discontinued just because they’ve switched Medicare Advantage plans or moved from traditional Medicare to Medicare Advantage.


EEOC Posts New Guidance on Visual Disabilities under the ADA

The Equal Employment Opportunity Commission has issued new guidance for employers to provide reasonable accommodations for visually impaired workers who request it.

About 18.4% of all American adults have at least some difficulty with their vision, even when wearing corrective lenses, according to the U.S. Centers for Disease Control and Prevention.

The new guidance addresses what employers who have a vision-impaired job applicant or worker can and can’t do under the Americans with Disabilities Act and what to do if they request, or if you want to offer them, specific accommodations to help them perform their jobs better and more safely (or help them complete the application process).

Under the ADA, if a worker with a disability asks for accommodation so they can better perform their job, their employer must enter into an interactive process with them to discuss ways that accommodation would be possible. You do not have to provide accommodation if doing so would be an “undue hardship.”

Here are the main points of the EEOC guidance:

Reasonable accommodation

The guidance lays out a number of accommodations that employers can provide for workers or job applicants with visual impairments, including:

  • Guide dogs,
  • Assistive technology, including:
    • Screen readers (or text-to-speech software). These are software applications that can convert written text on a computer screen into spoken words or a Braille display. These tools can allow individuals to quickly review written text.
    • Optical character-recognition technology that can create documents in screen-readable electronic form from printed ones, including an optical scanner (desktop, handheld or wearable).
    • Systems with audible, tactile or vibrating feedback, such as proximity detectors, which can alert individuals if they are too close to an object or another person.
    • Website modifications for accessibility. This entails taking steps to ensure that job applicants and employees can access and timely complete job applications, online tests or other screening tools.
  • Documents in Braille or large print.
  • Ambient adjustments (such as brighter office lights); and sighted assistance or services (such as a qualified reader).

Asking about vision impairment

According to the new guidance, applicants are not required to disclose they have any type of vision impairment or disability unless they are seeking a reasonable accommodation to assist with some aspect of the application process, such as a larger font or Braille on the written application.

Employers cannot generally ask questions about obvious vision impairment. However, if you “reasonably believe” the applicant will need an accommodation to perform the job, you may ask if one is needed, and if so, what type.

For example, if a job applicant uses a white cane when entering the room for a job interview, you can ask if they would need a reasonable accommodation in the workplace.

Once someone is hired or after they’ve received an offer, you may ask certain questions such as:

  • How long the applicant has had the vision impairment.
  • What, if any, vision the applicant has.
  • The applicant’s specific visual limitations and what reasonable accommodations may be needed to perform the job.

The takeaway

The EEOC guidance is expansive, and this article focuses on the main parts of it. Among the other areas it covers are:

  • How an employer should handle safety concerns about applicants and employees with visual disabilities.
  • How an employer can ensure that no employee is harassed because of a visual disability.
  • The importance of keeping medical records of workers with a vision disability confidential.
  • How to avoid discriminating against individuals who are vision-impaired.

Finally, considering that nearly one in five U.S. adults has some form of visual impairment, this guidance aims to help employers find a solution for reasonable accommodation. Many accommodations can be implemented with little cost to a business.

If you have questions about the new guidance, please call us.


Group Health Plan Affordability Level Cut Significantly for 2024

The IRS has significantly reduced the group plan affordability threshold — which is used to determine if an employer’s lowest-premium health plan meets the Affordable Care Act rules — for 2024.

The threshold for next year has been set at 8.39% of an employee’s household income, down significantly from 9.12% this year. The lower threshold will likely require employers to reduce their employees’ premium cost-sharing level for their lowest-cost plans in 2024, to avoid running afoul of the ACA.

This is happening just as group health plan premiums are expected to climb at a much faster clip in 2024 than the last three years.

Under the ACA, “applicable large employers” — that is, those with 50 or more full-time or full-time equivalent employees (FTEs)— are required to offer at least one health plan to their workers that is considered “affordable” based on a percentage of the lowest-paid employee’s household income.

The lowest level yet

The new level is the lowest affordability threshold since the ACA took effect, and almost one-and-half percentage points lower than the 9.89% threshold in 2021. The new threshold will apply to all health plans when they incept in 2024. For plans that incept after Jan. 1, the 2023 threshold will apply and change to the new rate when they renew later in the year.

Employers can rely on one or more safe harbors when determining if coverage is affordable:

  • The employee’s W-2 wages, as reported in Box 1 (at the start of 2022).
  • The employee’s rate of pay, which is the hourly wage rate multiplied by 130 hours per month (at the start of 2022).
  • The federal poverty level.

Example: The lowest-paid worker at Company A earns $25,987 per year. To meet the 2024 affordability requirement, they would have to pay no more than $2,180 a year in premium (or $181 a month).

Employers with a large low-wage workforce might decide to utilize the federal poverty level ($14,580 for 2024) affordability safe harbor to automatically meet the ACA affordability standard, which requires offering a medical plan option in 2024 that costs FTEs no more than $101.94 per month.

If an employee’s coverage is not affordable under at least one of the safe harbors and at least one FTE receives a premium tax credit for coverage they purchase on an ACA exchange, the employer may have to pay a penalty, known as the “employer shared responsibility payment.”

The shared responsibility payment for 2024 will be $4,460 per employee that receives a premium subsidy on an exchange, up from $4,320 this year.

The takeaway

As 2024 nears, you should review your health plan costs and premium-sharing to ensure that your lowest-cost plan complies with the affordability requirement.

We can help you assess affordability to ensure you don’t run afoul of the law. It will be particularly crucial in 2024, considering the significant drop in the threshold.