As Chicagoan's braced for another sweltering weekend, officials urged residents to stay cool after the National Weather Service declared the area's second heat warning of the summer.The weather service said Friday that high temperatures and humidity could push the heat index above 100 degrees through early next week. Excessive heat has been predicted for 19 Illinois counties.The danger of multiple, scorching days, officials warned, is the cumulative effect of heat on the body. "Each day of a heat wave is more deadly than the day before," said Dr. William Paul, deputy commissioner of the Chicago Department of Public Health. But, he said, heat-related deaths are preventable.
To avoid heat-induced illnesses, Paul emphasized that cooling off even for two to three hours on extremely hot days can help the body cope. People living without air-conditioning are encouraged to visit cooling centers, take cool baths or showers and drink at least eight glasses of water a day.
Since the summer's first heat wave swept through the region two weeks ago, officials have attributed eight deaths to the heat, with the victims ranging from age 49 to 79.
On Friday, officials in Cicero said the death of a 6-month-old girl may have been heat-related. An autopsy of the child will be performed Saturday, police said.
Officials are responding to the heat wave by opening cooling centers across the city and suburbs and extending hours at some senior centers. In Chicago, four senior centers will have extended hours. Other cooling centers include district police stations, libraries and park facilities.The Chicago Department on Aging will place calls to high-risk seniors and will team up with the Department of Human Services to conduct well-being checks requested through phone calls to 311, the city's information number.
www.medquote.com
www.medequote.net
www.unicaresoundplans.com
Saturday, July 29, 2006
Friday, July 28, 2006
UniCare Sound Plans
UniCare Sound Health Plans are a new product for resident of Illinois, and Texas. The plan has proven to be the most popular plan in whatever area it is marketed in. Simply put it is the best deal in health insurance today.
UniCare's Sound Health Plan is the perfect plan if you are single, between the ages of 18-40, and live in Illinois, or Texas. It is the perfect student health plan, the perfect plan while you are waiting for the next job, the perfect plan for when you are single, and it is real health insurance that limits your losses to the deductible.
Sound is Health coverage for your body, eyes, teeth. You know, the important stuff. Three simple health insurance plans, one just your flavor. Apply online, that's it. No catches, no wasted time.
Brought to you by your tight bud's at UniCare Health Insurance Company of the Midwest.
How Much you Could Save?
Sure, paying for health insurance is a pain. But not having it can hurt a lot more. Accidents and illness can happen even if you think you are invincible. You blow out a knee, or have appendicitis, your faced with a $30,000 hospital bill, but with Unicare Sound you will only pay $1,500 to $5,000 for the year depending on the plan you choose to get rid of that bill.
What's the Deal?
Here it is. Health insurance, straight up. Three plans. Same all-around coverage: preventive, emergency, Rx, eyes, teeth.
Compare Plans
See how much you can save. Pick the plan that fits. Then go play. The differences: What you pay, the deductible. We pay the rest at 100% with no hassles, or paperwork.
Gravity Bender...A.K.A. 5000
You live life on the edge, and happily go over it.
In network: unlimited doctor visits per year
$40 co-pay
Dental, Vision, Rx, ER, Preventative
$5,000 annual deductible
$67-$91 per month
Apply Online at www.unicaresoundplans.com
Curb Jumper...A.K.A. 3000
Play hard. Play safe. You mix it up any which way.
In network: unlimited doctor visits per year
$40 co-pay
Dental, Vison, Rx, ER, Preventative
$3,000 annual deductible
$67-$91 per month
Apply online at www.unicaresoundplans.com
The Cruiser...A.K.A. 1500
A well-thought-out walk on the wild side is just your style.
In network: Unlimited doctor visits per year
$40 co-pay
Dental, Vision, Rx, ER, Wellness, Preventative
$1,500 annual deductible
$85-$114 per month
Apply Online at www.unicaresoundplans.com
UniCare's Sound Health Plan is the perfect plan if you are single, between the ages of 18-40, and live in Illinois, or Texas. It is the perfect student health plan, the perfect plan while you are waiting for the next job, the perfect plan for when you are single, and it is real health insurance that limits your losses to the deductible.
Sound is Health coverage for your body, eyes, teeth. You know, the important stuff. Three simple health insurance plans, one just your flavor. Apply online, that's it. No catches, no wasted time.
Brought to you by your tight bud's at UniCare Health Insurance Company of the Midwest.
How Much you Could Save?
Sure, paying for health insurance is a pain. But not having it can hurt a lot more. Accidents and illness can happen even if you think you are invincible. You blow out a knee, or have appendicitis, your faced with a $30,000 hospital bill, but with Unicare Sound you will only pay $1,500 to $5,000 for the year depending on the plan you choose to get rid of that bill.
What's the Deal?
Here it is. Health insurance, straight up. Three plans. Same all-around coverage: preventive, emergency, Rx, eyes, teeth.
Compare Plans
See how much you can save. Pick the plan that fits. Then go play. The differences: What you pay, the deductible. We pay the rest at 100% with no hassles, or paperwork.
Gravity Bender...A.K.A. 5000
You live life on the edge, and happily go over it.
In network: unlimited doctor visits per year
$40 co-pay
Dental, Vision, Rx, ER, Preventative
$5,000 annual deductible
$67-$91 per month
Apply Online at www.unicaresoundplans.com
Curb Jumper...A.K.A. 3000
Play hard. Play safe. You mix it up any which way.
In network: unlimited doctor visits per year
$40 co-pay
Dental, Vison, Rx, ER, Preventative
$3,000 annual deductible
$67-$91 per month
Apply online at www.unicaresoundplans.com
The Cruiser...A.K.A. 1500
A well-thought-out walk on the wild side is just your style.
In network: Unlimited doctor visits per year
$40 co-pay
Dental, Vision, Rx, ER, Wellness, Preventative
$1,500 annual deductible
$85-$114 per month
Apply Online at www.unicaresoundplans.com
Saturday, July 22, 2006
Blagojevich allocates another $5 million to stem cell research
For a second straight year, Gov. Rod Blagojevich used his executive powers Thursday to order millions of dollars in state funds to be used for stem cell research, bypassing a state legislature conflicted on the controversial issue.Acting just a day after President Bush issued his first-ever veto in rejecting an expansion of federal funding for embryonic stem cell research, the Democratic governor ordered $5 million be available for grants on top of $10 million he announced last July.Illinois Senate Republicans accused Blagojevich of again subverting the will of the legislature, which has been sharply divided on the issue--particularly embryonic stem cell research. Lawmakers objected to Blagojevich's efforts to specifically earmark stem cell research funding in the state budget they approved in May.As he did last July, Blagojevich justified his move as an effort to help advance medical progress. He has used populist health-related initiatives, such as expanded children's insurance coverage, as a cornerstone of his re-election campaign.Blagojevich said Bush's actions made it clear that "stem cell research will get no support from Washington as long as he occupies the White House" while state lawmakers "had yet to back a plan" for providing research support."It would be wrong to ask sick and injured people and their loved ones to wait for the tides in Springfield and Washington to change before research into potentially life-saving cures can move forward," he said.Blagojevich aides said they could not determine how much of the $5 million would go to grants involving embryonic stem cells--the most politically controversial aspect of stem cell research--until the recipients were selected. Some conservatives, including Bush, oppose embryonic stem cell studies because they involve the destruction of human embryos.Senate Republicans said the Illinois legislature has answered the governor on this issue."The General Assembly has on at least two occasions debated this issue and rejected it," said Patty Schuh, spokeswoman for Senate Minority Leader Frank Watson (R-Greenville).Last July, after failed legislative attempts to set aside money for stem cell research, Blagojevich announced that he would fund such grants using $10 million that had been tucked into the state's budget under the generic heading of "scientific research." The line item did not mention the words stem cell, which angered opponents who said Blagojevich was trying to circumvent the legislature.After that experience, Sen. Dale Righter (R-Mattoon) said he asked directly this year on the Senate floor whether this year's budget would include any funding for stem cell research.Sen. Donne Trotter (D-Chicago), the top budget negotiator for Senate Democrats, said he told Righter that the budget didn't contain money for stem cell research because there was no specific line item for it.Trotter said the governor was able to find $5 million in the administrative budget of the Department of Healthcare and Family Services for stem cell research, partly because the cost of implementing All Kids, the governor's health-insurance plan for children, and other health programs was lower than projected."This wasn't our original intention during the budget process," said Blagojevich spokesman Abby Ottenhoff. "But in light of the president's veto yesterday, it's really the only option to make sure that stem cell research continues."
www.medequote.com
www.medequote.net
www.unicaresoundplans.com
www.tonikhealthquotes.com
www.medequote.com
www.medequote.net
www.unicaresoundplans.com
www.tonikhealthquotes.com
Thursday, July 20, 2006
Napierville snuffs out smoking
California snuffed out smoking in bars and restaurants eight years ago. Hinsdale, Burr Ridge, Chicago and most recently Oak Park followed with similar smoke-free ordinances.On Tuesday, the Naperville City Council took the first steps toward banning smoking in public places, including bars and restaurants. Heeding the call of a grass-roots anti-smoking group, the council unanimously agreed to take up the issue and directed city staff to draft sample ordinances for consideration in August.
Tuesday, July 18, 2006
Doubts about Illinois All Kids program
When Gov. Rod Blagojevich signed it last fall, the All Kids legislation was heralded as one of the nation's most ambitious plans to ensure that all children would have access to health insurance, regardless of their immigration status.Now, as the program's benefits have begun to roll out, thousands of families and doctors are wondering whether the broad-reaching effort will live up to its promise.
Illinois officials said the program, which launched July 1, was designed to cover medical, dental and vision visits as well as prescription drugs for those 18 and younger. It targets working-class families that can't afford private insurance but earn too much to qualify for Medicaid. New Mexico and Hawaii have established similar youth health benefits, and Massachusetts' new near-universal program includes provisions to increase coverage for uninsured minors.
Legislators in at least eight other states are examining proposals that would guarantee affordable coverage for minors. And as the country heads into midterm elections, universal coverage for children has broad popular support: 83% of voters in California, for example, supported state proposals to make sure every child had health insurance, according to a recent poll conducted for the United Way."It's more than just politics, though," said Jocelyn Guyer, senior program director at the Center for Children and Families at Georgetown University's Health Policy Institute. "Kids not having coverage is a huge problem, and it's only getting bigger."
The goal of All Kids is to fill the gap between where the federal government leaves off and where the private sector begins. An estimated 250,000 children in Illinois do not have health insurance.So far, more than 43,000 children have been enrolled in All Kids; the state hopes to enroll 50,000 in the first year. How much a family pays at the doctor's office depends on its income. For example, a family of four that makes $40,000 to $60,000 a year would be billed a $10 co-payment for each doctor visit and $40 a month per child, according to program officials.
The program is to be funded by a combination of patient fees, federal funds and cuts to other state healthcare expenses. Part of the costs will be covered by changing how the state's 1.7 million Medicaid patients see their doctors. Instead of visiting any physician on a list, those beneficiaries will be assigned a single doctor — a system modeled after health-management organizations."To me, healthcare is a fundamental human right," Blagojevich said. "If it's OK for the governor's two young children to have regular visits to the doctors for checkups … then the golden rule teaches us we should do for others as others would do for you."
Yet some critics question whether All Kids, which is expected to cost $45 million in its first year, will be able to deliver on its promise. They fear the program could end up costing more than expected, which could strain an already tight state budget."We've seen lots of promises with All Kids and little else," said state Sen. Peter Roskam (R-Wheaton), who has criticized the program's design. "How much of this is politics, and how much of this is trying to do the right thing?"Blagojevich, who has turned the program into a cornerstone of his reelection campaign this year, countered: "This is an affordable healthcare program, not a free one."Medical professionals have varying opinions about the program.
Some are optimistic — "It's something we've needed for years," said Dr. Mark Rosenberg, past president of the Illinois chapter of the American Academy of Pediatrics — whereas others have serious concerns about the program's long-term success."We have trouble with the state Medicaid program paying bills on time. We haven't been told if patients are going to know where to go for treatment, or how we're supposed to deal with referrals," said Dr. Peter Eupierre, president of the Illinois State Medical Society. "There are too many unanswered questions for our comfort."Blagojevich said he spearheaded All Kids in response to appeals from voters, who said they could not afford regular medical checkups for themselves or their children, and couldn't afford treatment if they got sick.An estimated 46 million people in America lack health insurance, according to the U.S. Census Bureau, and some state and local governments are trying to step in and fill the gap.
The federal government has tried to make cuts into Medicaid, and there's concern that they'll try to duplicate the same cuts here," said Peter Harbage, an independent consultant and former assistant secretary with the California Health and Human Services Agency. "Without those federal dollars, these state programs will be in serious trouble."
Illinois officials said the program, which launched July 1, was designed to cover medical, dental and vision visits as well as prescription drugs for those 18 and younger. It targets working-class families that can't afford private insurance but earn too much to qualify for Medicaid. New Mexico and Hawaii have established similar youth health benefits, and Massachusetts' new near-universal program includes provisions to increase coverage for uninsured minors.
Legislators in at least eight other states are examining proposals that would guarantee affordable coverage for minors. And as the country heads into midterm elections, universal coverage for children has broad popular support: 83% of voters in California, for example, supported state proposals to make sure every child had health insurance, according to a recent poll conducted for the United Way."It's more than just politics, though," said Jocelyn Guyer, senior program director at the Center for Children and Families at Georgetown University's Health Policy Institute. "Kids not having coverage is a huge problem, and it's only getting bigger."
The goal of All Kids is to fill the gap between where the federal government leaves off and where the private sector begins. An estimated 250,000 children in Illinois do not have health insurance.So far, more than 43,000 children have been enrolled in All Kids; the state hopes to enroll 50,000 in the first year. How much a family pays at the doctor's office depends on its income. For example, a family of four that makes $40,000 to $60,000 a year would be billed a $10 co-payment for each doctor visit and $40 a month per child, according to program officials.
The program is to be funded by a combination of patient fees, federal funds and cuts to other state healthcare expenses. Part of the costs will be covered by changing how the state's 1.7 million Medicaid patients see their doctors. Instead of visiting any physician on a list, those beneficiaries will be assigned a single doctor — a system modeled after health-management organizations."To me, healthcare is a fundamental human right," Blagojevich said. "If it's OK for the governor's two young children to have regular visits to the doctors for checkups … then the golden rule teaches us we should do for others as others would do for you."
Yet some critics question whether All Kids, which is expected to cost $45 million in its first year, will be able to deliver on its promise. They fear the program could end up costing more than expected, which could strain an already tight state budget."We've seen lots of promises with All Kids and little else," said state Sen. Peter Roskam (R-Wheaton), who has criticized the program's design. "How much of this is politics, and how much of this is trying to do the right thing?"Blagojevich, who has turned the program into a cornerstone of his reelection campaign this year, countered: "This is an affordable healthcare program, not a free one."Medical professionals have varying opinions about the program.
Some are optimistic — "It's something we've needed for years," said Dr. Mark Rosenberg, past president of the Illinois chapter of the American Academy of Pediatrics — whereas others have serious concerns about the program's long-term success."We have trouble with the state Medicaid program paying bills on time. We haven't been told if patients are going to know where to go for treatment, or how we're supposed to deal with referrals," said Dr. Peter Eupierre, president of the Illinois State Medical Society. "There are too many unanswered questions for our comfort."Blagojevich said he spearheaded All Kids in response to appeals from voters, who said they could not afford regular medical checkups for themselves or their children, and couldn't afford treatment if they got sick.An estimated 46 million people in America lack health insurance, according to the U.S. Census Bureau, and some state and local governments are trying to step in and fill the gap.
The federal government has tried to make cuts into Medicaid, and there's concern that they'll try to duplicate the same cuts here," said Peter Harbage, an independent consultant and former assistant secretary with the California Health and Human Services Agency. "Without those federal dollars, these state programs will be in serious trouble."
Monday, July 17, 2006
Considering a retirement home brings up some good questions.
Moving late in life is hard. First you must come to terms with the idea, then decide where to go. As one reader wrote, "I'm an active 89 this month and having a terrible time deciding what retirement home I should select. Time to move, I'm sure — but where?"
Here's where the "tire-kicking" comes in doing your homework to find the right place. While the decision can be tough, it can also open doors to a renewed and more convenient quality of life. What's hard is the unknown until you know it.
So where do you start? One step at a time.
• Know what services are available and their costs.
• Decide which of these services is appropriate, based on your functional needs, now and in the future. You can download my "Older Adult Assessment" form in the related links area of this article.
If you're healthy, you'll look for an independent retirement community that offers additional services for later.
If you have difficulty with daily chores, can't walk, have Alzheimer's, or need medical attention, you're more likely to need an assisted-living facility, adult family home or nursing home.
Whatever the choice, the basic questions are similar.
1. What are the fee structure and costs?
Private-pay. Fees are based on the living space you choose, with higher rates for such amenities as a view, large square-footage or a deck. Some facilities charge a fixed amount, while others add on fees for the services you use. This might be stated as a "level" of care for, say, two hours of staff time a day; "à la carte," meaning each item you use has a price, such as assistance with medications and bathing; or a "point" system that covers a group of services.
Ask about the facility's history of price increases, whether there's a one-time move-in fee or pet deposit. What happens if you run out of money?
Government funding may be available if you need care (not if you're healthy), but availability varies widely. Medicare, for example, is available only in nursing homes, while Medicaid or COPES (for those who've spent down their assets) is in a few assisted-living facilities (the state calls them "boarding homes"), some adult family homes, and most nursing homes.
2. Is space available now? Is there a waiting list? What happens if you're not ready when they call? Is there a fee to be wait-listed?
3. Special needs: If it's appropriate, be sure to ask whether the facility can provide low-salt or diabetic meals, help with insulin shots, lifting or other medical assistance. These require special staff (mainly nurses) and equipment, and some places don't have them.
4. Food: How many meals are provided each day? What choices do you have if you don't like what's served? Can you have a fried egg anytime you want? Most facilities welcome visitors for lunch, so be sure to sample amply, since the quality and taste can be a deal-breaker.
5. Pay attention to the activity schedule and, if you can, observe what happens. A good activity director is worth her weight in gold.
6. How does the facility assess your condition as it changes, and what happens then?
7. In adult family homes, where only one person may provide care day and night, how does he or she take a break?
8. The long-term-care ombudsman's office, a state program (in every state) that advocates for residents' rights, sends volunteers to many facilities to visit. Does one come to this facility?
9. Does the facility accept residents with memory loss? If so, is there a special section for them, with special activities and trained staff? At what point is someone with dementia required to move?
You can get answers to some of these questions by telephone. However, the best way to gauge whether a facility fits your needs is to visit. The more choices you experience, the easier it is to compare. And try to visit more than once. Make an appointment when you need in-depth information (such as for your first visit), then come unannounced on a different day and hour of the week to observe.
If you have a friend, daughter or son, bring that person, too. It's always good to have more than one set of eyes and ears helping you process this complicated information.
Remember, it's not the wallpaper that makes a place worthy of being your new home, but the quality of what goes on inside.
Use your senses: your eyes, ears, nose, taste and touch. Does the place smell? Does it seem clean? Is it pleasant? In nursing homes, are the call bells answered promptly? Do you hear irritation in staff voices? This may indicate staff shortages and overwork.
Do staff members know residents by name, and vice versa? Do they seem to like each other? Pull the emergency cord and see how quickly someone comes. Telephone during nonbusiness hours and leave a message. How promptly is it returned?
www.medequote.com
Here's where the "tire-kicking" comes in doing your homework to find the right place. While the decision can be tough, it can also open doors to a renewed and more convenient quality of life. What's hard is the unknown until you know it.
So where do you start? One step at a time.
• Know what services are available and their costs.
• Decide which of these services is appropriate, based on your functional needs, now and in the future. You can download my "Older Adult Assessment" form in the related links area of this article.
If you're healthy, you'll look for an independent retirement community that offers additional services for later.
If you have difficulty with daily chores, can't walk, have Alzheimer's, or need medical attention, you're more likely to need an assisted-living facility, adult family home or nursing home.
Whatever the choice, the basic questions are similar.
1. What are the fee structure and costs?
Private-pay. Fees are based on the living space you choose, with higher rates for such amenities as a view, large square-footage or a deck. Some facilities charge a fixed amount, while others add on fees for the services you use. This might be stated as a "level" of care for, say, two hours of staff time a day; "à la carte," meaning each item you use has a price, such as assistance with medications and bathing; or a "point" system that covers a group of services.
Ask about the facility's history of price increases, whether there's a one-time move-in fee or pet deposit. What happens if you run out of money?
Government funding may be available if you need care (not if you're healthy), but availability varies widely. Medicare, for example, is available only in nursing homes, while Medicaid or COPES (for those who've spent down their assets) is in a few assisted-living facilities (the state calls them "boarding homes"), some adult family homes, and most nursing homes.
2. Is space available now? Is there a waiting list? What happens if you're not ready when they call? Is there a fee to be wait-listed?
3. Special needs: If it's appropriate, be sure to ask whether the facility can provide low-salt or diabetic meals, help with insulin shots, lifting or other medical assistance. These require special staff (mainly nurses) and equipment, and some places don't have them.
4. Food: How many meals are provided each day? What choices do you have if you don't like what's served? Can you have a fried egg anytime you want? Most facilities welcome visitors for lunch, so be sure to sample amply, since the quality and taste can be a deal-breaker.
5. Pay attention to the activity schedule and, if you can, observe what happens. A good activity director is worth her weight in gold.
6. How does the facility assess your condition as it changes, and what happens then?
7. In adult family homes, where only one person may provide care day and night, how does he or she take a break?
8. The long-term-care ombudsman's office, a state program (in every state) that advocates for residents' rights, sends volunteers to many facilities to visit. Does one come to this facility?
9. Does the facility accept residents with memory loss? If so, is there a special section for them, with special activities and trained staff? At what point is someone with dementia required to move?
You can get answers to some of these questions by telephone. However, the best way to gauge whether a facility fits your needs is to visit. The more choices you experience, the easier it is to compare. And try to visit more than once. Make an appointment when you need in-depth information (such as for your first visit), then come unannounced on a different day and hour of the week to observe.
If you have a friend, daughter or son, bring that person, too. It's always good to have more than one set of eyes and ears helping you process this complicated information.
Remember, it's not the wallpaper that makes a place worthy of being your new home, but the quality of what goes on inside.
Use your senses: your eyes, ears, nose, taste and touch. Does the place smell? Does it seem clean? Is it pleasant? In nursing homes, are the call bells answered promptly? Do you hear irritation in staff voices? This may indicate staff shortages and overwork.
Do staff members know residents by name, and vice versa? Do they seem to like each other? Pull the emergency cord and see how quickly someone comes. Telephone during nonbusiness hours and leave a message. How promptly is it returned?
www.medequote.com
Monday, July 10, 2006
Overcoming hurdles with Cobra
Under COBRA, an individual who might otherwise lose coverage under a group health plan can pay to continue that coverage for a limited time. Thus, under COBRA, an employer must give a “qualified beneficiary” who has had a qualifying event the opportunity to continue the health coverage that he or she was previously receiving before the qualifying event. Notice and disclosure obligations relating to the continuation coverage are imposed upon employers that sponsor COBRA-covered plans.COBRA applies to group health plans. Generally, a plan is a group health plan if it provides medical care and is maintained by the employer. Medical care, defined under section 213(d) of the Internal Revenue Code, includes the diagnosis, cure, mitigation, treatment, or prevention of disease and any undertaking affecting any structure or function of the body and is not just merely beneficial to an individual’s general health or well being. A group health plan can require a qualified beneficiary to pay an amount that does not exceed 102% of the “applicable premium” for the coverage. The “applicable premium” is the cost to the plan of providing coverage.When a plan offers DM, wellness or health improvement programs, how does this fit into the COBRA picture? Is the DM or wellness program part of the health plan or a health plan in and of itself? Should qualified beneficiaries be afforded the opportunity to continue in the DM or wellness program; and if yes, at what cost? Is continuation of the primary medical plan necessary to receive on-going DM benefits? Should the individual receive any premium discounts or other incentives?
It’s easy to raise questions, but not so easy to answer them. Often, there may be no clear answers. Some plans extend benefits (and even the discounts) to COBRA qualified beneficiaries; others do not. When it comes to DM programs and COBRA, it’s best to seek legal advice about whether or not COBRA requires that the program be extended to continuees. Several considerations come into play when analyzing whether COBRA continuation coverage must be extended in a particular DM program:
1. Consider what type of program it is -- DM, wellness or health improvement program. This may have bearing on whether the program would be considered a medical plan under COBRA. For example, a program that simply promotes healthy living or offers referrals may not be considered to be medical care. On the other hand, a program that promotes healthy living, but also provides smoking cessation and weight loss classes, in addition to counseling services and screening services with follow up consultations with program physicians would likely be considered to be medical care.
2. Consider what type of incentive is offered – cash, flex credits, premium reduction or discount or improved benefit? It seems fairly clear that if the incentive involves cash or a premium discount or reduction, COBRA would apply differently, or maybe not at all. COBRA only attaches to “medical care.”
3. Is the DM program part of the health plan, or a free-standing arrangement? Would it be considered a separate group health plan? Does the DM program offer medical coverage? Who delivers the DM program? Is it offered by an outside vendor? By the health issuer or employer health plan? Does it make a difference who provides the discount – the employer, the vendor, the insurer?The key here turns on whether the DM program offers medical care or would be considered medical care. If the DM program provides health credits, discounts or cash incentives when a participant fills out a health risk assessment, some argue the DM program is related to the cost of coverage and is not a medical benefit at all. Others believe that if a “premium discount” is offered for DM participation, it likely means that COBRA continuees must be offered an opportunity to participate (i.e., with or without the discount based on DM participation) in the primary medical plan with the premium discount. This especially seems to be the case where the DM incentive is deposited into a health reimbursement account.If the program is a “strict disease management program” that identifies individuals with risk factors once a claim is made, the services provided under the program (such as education, nurse contact to manage a chronic disease) seem to be clearly medical care provided through the employer. These services must be extended to COBRA continuees on the same basis as they are extended to active employees.What about a DM program where the incentive is related to benefit coverage? An example of this type program is one that offers a higher level of benefit (e.g., smaller copays, coinsurance, or deductibles) for coverage of individuals who participate in the DM program. It would appear that this type of incentive must also be offered to COBRA continuees since it relates to the coverage under a medical plan. This coverage also, however has a value. While the continuee might be entitled to the better coverage under the DM program, they will have to pay 102% of any additional cost to get the benefit. Of course an actuarial analysis must be undertaken to justify whether there is indeed an additional cost (or whether the DM participation may in fact reduce claims costs). (See discussion of premium later in the article.)If the program is of a “wellness” nature, the question of whether medical care is provided is less clear. A program that offers a health risk assessment and coaching services to promote a healthy lifestyle may not be considered medical care. A program that offers “targeted intervention” based on answers to the health risk assessment questions would more likely be construed as providing medical care. Much depends on what the “targeted intervention” entails. A program that offers smoking cessation or weight loss classes (rather than a referral to such classes) and provides screening and physician follow-up would likely be considered to offer medical care. It would seem appropriate in that instance to extend the program to continuees.
4. Is the DM program extended to a larger “footprint” than active medical coverage? For example, many employers make the DM program available to all employees – even if they do not participate in the medical plan. In this case, a DM program that is deemed to be medical care would create COBRA obligations (and a continuation right) for all employees eligible for the DM benefit – even if they are not in the employer’s primary medical plan. This could substantially increase the administrative burden and cost on the plan sponsor. On the other hand, if the DM program is structured as part of the employer’s group health plan, COBRA rights could be restricted to those in the medical plan, and continuation coverage obligations could be integrated into the active plan’s COBRA regime.
5. Ultimately, COBRA is not just about continuing medical care, but paying 102% of the actual cost of that medical care. Even if a DM program would be considered employer provided medical care, the COBRA premium for such care is 102% of the actual cost. An employer has wide discretion to determine the number of group health plans it maintains. If the DM program is a separate plan, or priced separately, this determination is easy. In many cases, to accommodate COBRA, employers will be required to offer a COBRA rate with the DM program included in the health plan, and/or a rate with the DM program excluded.Note that if the employer considers the DM program to be a separate medical plan, a COBRA notice obligation could also arise.The issues presented here can be complex and intricate. In reality, probably few employers adequately consider the COBRA implications when it comes to their DM programs, particularly the ones that relate to healthy living or wellness program and those that offer cash incentives. As incentives for participation in these programs tie them tighter to medical benefits though, employers will have to carefully consider the COBRA implications. When COBRA applies, as a general rule, the plan sponsor must give COBRA continuees the same DM privileges as are extended to active employees. Employers will need their legal counsel to help them sort out all the issues.B. Taxability ConcernsAs noted above, as an inducement for employees to complete a health risk assessment, many DM Programs provide financial incentives (the “carrot”) to employees for completing the health risk assessment. These financial incentives often take the form of gift certificates, cash, premium reductions or dollars in an HRA, FSA, or HSA. When the incentive is couched in terms of a health benefits, such as a premium reduction or a payment into a health FSA, HRA or HSA, the incentive may be excluded from taxation. When the incentive is couched in terms of a gift certificate, gift card or coupon or cash bonus, the incentive will be included in income and will be taxable. Often the infrastructure does not exist to properly address tax issues associated with DM financial incentives.
1. Premium Incentives - If an employer offers an incentive (or disincentive) related to a health premium, such as reduction in a health premium, a premium holiday, or a contribution to a health FSA, HRA or HSA (or a premium increase), the amount of that incentive will be excluded from the employee’s gross income pursuant to sections 105 and 106 of the Internal Revenue Code. Like other employer provided health benefits, an incentive of this nature will receive the same tax treatment. The incentive will not be included in the employee’s gross income. Additionally, the incentive will be excluded from employment taxes (FICA and FUTA, generally) and will be a deductible business expense for the employer (under section 162 (a)).
2. Cash Incentives - If the employer offers an incentive that takes the form of cash, such as a bonus or a gift certificate or card, the incentive will likely be taxable and should be included in the employee’s gross income as compensation. In some cases, it may be possible that an incentive offered in the form of an employee discount or meal, for example, could be excludable from the employee’s gross income because it is considered a fringe benefit under section 132. But these instances are rare. The more common situation, however, is where the employer offers a gift certificate, card, coupon (or outright cash) to the employee that participates in the DM program. These types of incentives will not qualify as nontaxable fringe benefits. The IRS treats gift certificates, card or coupons as cash equivalents. Cash to an employee is treated as compensation and is always taxable under section 61 of the Code. These incentive amounts will be subject to employment tax reporting and additional withholding obligations.In addition, if the DM financial incentives are paid through a VEBA, the VEBA’s tax-free status may be jeopardized, even though the incentive is tied to a permissible benefit (the health plan and DM Program). This is because VEBAs must generally provide only certain permissible benefits (e.g., healthcare). VEBAs may provide some level of other (e.g., impermissible) benefits, but the level of such impermissible benefits must be “de minimis” when compared to other benefits offered under the VEBA. There is no definition of “de minimis,” in the Code or Treasury Regulations, but IRS rulings related to domestic partner benefits seem to use 3% as the threshold. While such incentives may be de minimis when considered separately, when combined with additional “non-health” benefits the incentive could raise exceed the 3% threshold. For example, if the VEBA presently pays benefits for domestic partners (also an impermissible benefit), the addition of the DM financial incentive might send the entire amount over the VEBA’s “de minimis” limit.
3. Incentives Can Raise Nondiscrimination Red Flags - Although not intentional, DM incentives could cause nondiscrimination issues under sections 105(h) (self–insured medical plans) and/or 125 (cafeteria plans). Nondiscrimination issues could arise depending on the employees who choose to participate in the program and receive the incentive. Those that receive the incentive, depending on the nature of the incentive (e.g., cash vs. premium reduction), could also get a better benefit under the self-insured medical plan and/or cafeteria plan which could, in turn, affect nondiscrimination testing. Incentives could affect the benefits test under section 105(h) and the key employee concentration and the benefit and contributions tests under section 125.
As a result of these tax issues, plan sponsors should seek the advice of competent benefits counsel to weigh the pros and cons of the type of incentives to offer, and to decipher potential tax issues.C. Compliance Concerns That May Arise When DM Programs are Integrated With HSAs or HRAsIn light of the tax and VEBA compliance issues associated taxable financial incentives, many employers seek to direct incentives toward tax-free health savings account (HSA) or health reimbursement arrangement (HRA) benefits. As discussed in this section, great care should be exercised to ensure that the applicable operating rules associated with HSA and HRA arrangements are not violated.
1. HSAs and the Comparability Requirement - As employers search for new ways to keep illness and health plan spending down and promote wellness programs, HSAs are often considered. An employer that sponsors an HSA is not required to make HSA contributions. However, if an employer makes HSA contributions, the employer is subject to a 35% excise tax on all of its HSA contributions made during the calendar year unless it “makes available comparable contributions to the [HSAs] of all comparable participating employees for each month during such calendar year.” Generally, if an employer makes contributions to HSAs, it must contribute the same amount or the same percentage of the deductible to all employees who are eligible individuals, and who have the same coverage category (self-only or family). The employer may, however, restrict its contributions to those eligible individuals covered under the employer’s HDHP provided that the employer makes no contributions to any employee not covered under the employer’s HDHP. Also, the test may be run separately for “part-time employees”, which is statutorily defined as those who customarily work fewer than 30 hours per week. We call this the “HSA comparability rule.”Unfortunately, this inflexible “comparability” requirement does not fit well with the goal of rewarding DM Program participants with HSA-based financial incentives for DM participation. However, the HSA comparability rule does not apply when employer contributions (including matching contributions and bonuses for disease management and wellness programs) are “made through a Section 125 cafeteria plan”. IRS Notice 2004-50 includes the following discussion:Q-49. If under the employer’s cafeteria plan, employees who are eligible individuals and who participate in health assessments, disease management programs or wellness programs receive an employer contribution to an HSA, unless the employee elects cash, are the contributions subject to the section 4980G comparability rules?A-49. No. The comparability rules under section 4980G do not apply to employer contributions to an HSA through a cafeteria plan.Employers struggle, however, with this concept of a DM-based HSA contribution being made “through a cafeteria plan.” Exactly when is a contribution considered to be made "through a cafeteria plan?" If the example above is read too literally, it would seem that a “cash” incentive must always be available for the DM incentive to be offered through the cafeteria plan.
2. HRAs and DM IncentivesMany consumer-driven healthcare arrangements include a health reimbursement arrangement (HRA) under which unused funds carry forward into subsequent years. Often plan sponsors seek to include the DM financial incentive as part of the HRA – i.e., participating in the wellness or DM program results in an increased HRA contribution. As discussed below, this plan design may create compliance issues under the current HRA rules.Currently, employer contributions to an HRA may NOT be attributable in whole or part to pre-tax salary reductions made under a cafeteria plan. In addition, an HRA may not be funded with benefit credits that could otherwise be received as cashable compensation. This does not mean that the HRA cannot be offered in conjunction with a major medical plan (e.g., an HDHP) that is funded in part with employee pre-tax contributions. However, the “no direct/indirect” funding requirement must be satisfied in order for the HRA to be offered with a medical plan that is offered under the cafeteria plan – i.e., employee salary reductions (or employer cashable credits) cannot fund the HRA either directly or indirectly.No direct funding of HRA: The first condition is satisfied if employee pre-tax salary reduction amounts do not directly fund the HRA. Direct funding does not occur if (i) the salary reduction agreement indicates that salary reductions are used solely for the non-HRA portion of the major medical plan, and (ii) the employee pre-tax salary reductions for the major medical plan are less than the applicable COBRA premium for such coverage. For example, if the applicable COBRA premium for single major medical coverage is $1,800 per year, the annual salary reduction election for such coverage must be less than $1,800. The applicable COBRA premium is generally the cost to the plan to provide such coverage. The 2% administrative charge permitted by COBRA is in addition to the applicable premium. The salary reduction must be less than the applicable premium for such coverage without consideration of the 2% administrative charge.No indirect funding of HRA: A substantially less clear condition is that the HRA cannot interact with a cafeteria plan in such a way that it is indirectly funded with pre-tax salary reductions. IRS HRA guidance indicates that where an employee who participates in an HRA has a choice among two or more medical plan options to be used in conjunction with the HRA (or a choice among various maximum reimbursement amounts), and there is a correlation between the maximum reimbursement amount under the HRA and the salary reduction election for a specified medical plan, then the salary reduction is attributed to the HRA, even if the salary reduction is less than the applicable COBRA premium. For example, an employer may not permit an employee to choose a higher salary reduction amount for a particular level of specific medical plan coverage in order to receive a higher HRA amount. In the example provided by the IRS HRA guidance, the employer offers family medical coverage worth $4,500. The employee may choose to contribute on a pre-tax salary reduction basis either $2,500 or $3,500 for such coverage. If the employee elects the $2,500 salary reduction option, the employee receives a $1,000 credit to his or her HRA. If the employee elects the $3,500 salary reduction option, he or she will receive a much higher HRA credit of $2,000. The example set forth in the guidance (and discussed above) indicates that an employee cannot have a choice between a higher salary reduction amount and a higher HRA. Thus, it may be permissible to offer multiple medical plan options in conjunction with the HRA provided that HRA reimbursement amounts increase as salary reduction amounts decrease.
For example, assume an employer offers two medical plan options in conjunction with an HRA. Option 1 offers major medical with a $3,000 deductible. The applicable premium for such coverage for the year is $2,000. The required salary reduction amount is $500 and the HRA amount is $2,000.
Alternatively, employees can choose Option 2, which offers a major medical plan with a $4,000 deductible and an applicable premium of $1,500. The salary reduction amount for Option 2 is $300 and the HRA is $3,000. This would appear to be permissible because the employee is not electing a higher salary reduction amount for a higher HRA (it is quite the opposite).The IRS HRA guidance identifies two other situations where the salary reduction is attributable to the HRA, even though the salary reduction amount is less than the applicable COBRA premium. One, an HRA is deemed to be indirectly funded with pre-tax salary reductions if the employee may choose to apply the HRA amount toward the employee’s share of medical plan coverage in lieu of the pre-tax salary reduction. Two, an HRA is deemed to be indirectly funded with pre-tax salary reductions if the amount credited to the HRA is related to an amount forfeited under a Health FSA. Impact of HRA Rules on DM financial incentives: Health plan sponsors must be especially vigilant of the HRA indirect funding rules when designing their DM financial incentive arrangements. For example, an employer that creates a DM health incentive for all employees that participate in a specified disease management or wellness program may run afoul of the HRA indirect funding rule if the DM financial incentive is deposited in an HRA. Consider the following: Wellco currently has two health plan options. A PPO option with an employee contribution rate of $100 per month and a high deductible HRA option with an employee contribution of $200 per month with $100 per month accruing in an HRA. Wellco is considering a DM incentive whereby employees in either option can receive a $10 per month HRA credit for completing a health risk assessment. Are there any issues under the HRA indirect funding rule? Under the above arrangement, it appears that participants have a choice of the Wellco PPO option or HRA option – both of which have a related DM HRA. While the PPO option has a DM HRA, additional HRA contributions can be obtained by electing to salary reduce an additional $100 per month and electing the HRA option (in lieu of the PPO). This could be considered to be a violation of the indirect funding rule. The amount of the HRA accrual for the DM incentive for the PPO option is less than the HRA accrual for the HRA option. Therefore, if the salary reduction amount for the health coverage under the HRA health coverage option is greater than the salary reduction amount for the health coverage offered with the PPO Plan, then there may be an indirect funding issue -- i.e., the HRA accrual increases in tandem with the salary reduction. Arguments can be made that the Wellco plan does not violate the indirect funding rule – e.g., indeed, the DM incentive is equally available regardless of salary reduction contribution amount. However, once this issue is identified, conservative employers may wish to evaluate a couple of alternatives to possibly eliminate the "indirect funding" issue. First, given the nominal amount of the DM HRA, perhaps it could be offered without a carryover -- thus making it an FSA but not an HRA at all. This would facilitate offering the DM incentive without adversely affecting the indirect funding rule. Alternatively, depending on pricing and benefit offerings, if the HRA option has a lower salary reduction requirement than the PPO option, then an indirect funding issue should not arise.Needless to say, great care should be taken in designing a DM incentive program to ensure that the direct/indirect funding rules are not violated.ConclusionWe have examined the ADA, HIPAA nondiscrimination as well as privacy, COBRA, ADEA, and tax issues (HSA and HRA issues) related to DM programs. While DM programs continue to gain popularity and make their mark on the healthcare industry, employers should take care to take a measured approach looking at the whole picture, including the benefits compliance issues associated with such arrangements.
www.unicaresoundplans.com
www.medequote.com
www.medequote.net
It’s easy to raise questions, but not so easy to answer them. Often, there may be no clear answers. Some plans extend benefits (and even the discounts) to COBRA qualified beneficiaries; others do not. When it comes to DM programs and COBRA, it’s best to seek legal advice about whether or not COBRA requires that the program be extended to continuees. Several considerations come into play when analyzing whether COBRA continuation coverage must be extended in a particular DM program:
1. Consider what type of program it is -- DM, wellness or health improvement program. This may have bearing on whether the program would be considered a medical plan under COBRA. For example, a program that simply promotes healthy living or offers referrals may not be considered to be medical care. On the other hand, a program that promotes healthy living, but also provides smoking cessation and weight loss classes, in addition to counseling services and screening services with follow up consultations with program physicians would likely be considered to be medical care.
2. Consider what type of incentive is offered – cash, flex credits, premium reduction or discount or improved benefit? It seems fairly clear that if the incentive involves cash or a premium discount or reduction, COBRA would apply differently, or maybe not at all. COBRA only attaches to “medical care.”
3. Is the DM program part of the health plan, or a free-standing arrangement? Would it be considered a separate group health plan? Does the DM program offer medical coverage? Who delivers the DM program? Is it offered by an outside vendor? By the health issuer or employer health plan? Does it make a difference who provides the discount – the employer, the vendor, the insurer?The key here turns on whether the DM program offers medical care or would be considered medical care. If the DM program provides health credits, discounts or cash incentives when a participant fills out a health risk assessment, some argue the DM program is related to the cost of coverage and is not a medical benefit at all. Others believe that if a “premium discount” is offered for DM participation, it likely means that COBRA continuees must be offered an opportunity to participate (i.e., with or without the discount based on DM participation) in the primary medical plan with the premium discount. This especially seems to be the case where the DM incentive is deposited into a health reimbursement account.If the program is a “strict disease management program” that identifies individuals with risk factors once a claim is made, the services provided under the program (such as education, nurse contact to manage a chronic disease) seem to be clearly medical care provided through the employer. These services must be extended to COBRA continuees on the same basis as they are extended to active employees.What about a DM program where the incentive is related to benefit coverage? An example of this type program is one that offers a higher level of benefit (e.g., smaller copays, coinsurance, or deductibles) for coverage of individuals who participate in the DM program. It would appear that this type of incentive must also be offered to COBRA continuees since it relates to the coverage under a medical plan. This coverage also, however has a value. While the continuee might be entitled to the better coverage under the DM program, they will have to pay 102% of any additional cost to get the benefit. Of course an actuarial analysis must be undertaken to justify whether there is indeed an additional cost (or whether the DM participation may in fact reduce claims costs). (See discussion of premium later in the article.)If the program is of a “wellness” nature, the question of whether medical care is provided is less clear. A program that offers a health risk assessment and coaching services to promote a healthy lifestyle may not be considered medical care. A program that offers “targeted intervention” based on answers to the health risk assessment questions would more likely be construed as providing medical care. Much depends on what the “targeted intervention” entails. A program that offers smoking cessation or weight loss classes (rather than a referral to such classes) and provides screening and physician follow-up would likely be considered to offer medical care. It would seem appropriate in that instance to extend the program to continuees.
4. Is the DM program extended to a larger “footprint” than active medical coverage? For example, many employers make the DM program available to all employees – even if they do not participate in the medical plan. In this case, a DM program that is deemed to be medical care would create COBRA obligations (and a continuation right) for all employees eligible for the DM benefit – even if they are not in the employer’s primary medical plan. This could substantially increase the administrative burden and cost on the plan sponsor. On the other hand, if the DM program is structured as part of the employer’s group health plan, COBRA rights could be restricted to those in the medical plan, and continuation coverage obligations could be integrated into the active plan’s COBRA regime.
5. Ultimately, COBRA is not just about continuing medical care, but paying 102% of the actual cost of that medical care. Even if a DM program would be considered employer provided medical care, the COBRA premium for such care is 102% of the actual cost. An employer has wide discretion to determine the number of group health plans it maintains. If the DM program is a separate plan, or priced separately, this determination is easy. In many cases, to accommodate COBRA, employers will be required to offer a COBRA rate with the DM program included in the health plan, and/or a rate with the DM program excluded.Note that if the employer considers the DM program to be a separate medical plan, a COBRA notice obligation could also arise.The issues presented here can be complex and intricate. In reality, probably few employers adequately consider the COBRA implications when it comes to their DM programs, particularly the ones that relate to healthy living or wellness program and those that offer cash incentives. As incentives for participation in these programs tie them tighter to medical benefits though, employers will have to carefully consider the COBRA implications. When COBRA applies, as a general rule, the plan sponsor must give COBRA continuees the same DM privileges as are extended to active employees. Employers will need their legal counsel to help them sort out all the issues.B. Taxability ConcernsAs noted above, as an inducement for employees to complete a health risk assessment, many DM Programs provide financial incentives (the “carrot”) to employees for completing the health risk assessment. These financial incentives often take the form of gift certificates, cash, premium reductions or dollars in an HRA, FSA, or HSA. When the incentive is couched in terms of a health benefits, such as a premium reduction or a payment into a health FSA, HRA or HSA, the incentive may be excluded from taxation. When the incentive is couched in terms of a gift certificate, gift card or coupon or cash bonus, the incentive will be included in income and will be taxable. Often the infrastructure does not exist to properly address tax issues associated with DM financial incentives.
1. Premium Incentives - If an employer offers an incentive (or disincentive) related to a health premium, such as reduction in a health premium, a premium holiday, or a contribution to a health FSA, HRA or HSA (or a premium increase), the amount of that incentive will be excluded from the employee’s gross income pursuant to sections 105 and 106 of the Internal Revenue Code. Like other employer provided health benefits, an incentive of this nature will receive the same tax treatment. The incentive will not be included in the employee’s gross income. Additionally, the incentive will be excluded from employment taxes (FICA and FUTA, generally) and will be a deductible business expense for the employer (under section 162 (a)).
2. Cash Incentives - If the employer offers an incentive that takes the form of cash, such as a bonus or a gift certificate or card, the incentive will likely be taxable and should be included in the employee’s gross income as compensation. In some cases, it may be possible that an incentive offered in the form of an employee discount or meal, for example, could be excludable from the employee’s gross income because it is considered a fringe benefit under section 132. But these instances are rare. The more common situation, however, is where the employer offers a gift certificate, card, coupon (or outright cash) to the employee that participates in the DM program. These types of incentives will not qualify as nontaxable fringe benefits. The IRS treats gift certificates, card or coupons as cash equivalents. Cash to an employee is treated as compensation and is always taxable under section 61 of the Code. These incentive amounts will be subject to employment tax reporting and additional withholding obligations.In addition, if the DM financial incentives are paid through a VEBA, the VEBA’s tax-free status may be jeopardized, even though the incentive is tied to a permissible benefit (the health plan and DM Program). This is because VEBAs must generally provide only certain permissible benefits (e.g., healthcare). VEBAs may provide some level of other (e.g., impermissible) benefits, but the level of such impermissible benefits must be “de minimis” when compared to other benefits offered under the VEBA. There is no definition of “de minimis,” in the Code or Treasury Regulations, but IRS rulings related to domestic partner benefits seem to use 3% as the threshold. While such incentives may be de minimis when considered separately, when combined with additional “non-health” benefits the incentive could raise exceed the 3% threshold. For example, if the VEBA presently pays benefits for domestic partners (also an impermissible benefit), the addition of the DM financial incentive might send the entire amount over the VEBA’s “de minimis” limit.
3. Incentives Can Raise Nondiscrimination Red Flags - Although not intentional, DM incentives could cause nondiscrimination issues under sections 105(h) (self–insured medical plans) and/or 125 (cafeteria plans). Nondiscrimination issues could arise depending on the employees who choose to participate in the program and receive the incentive. Those that receive the incentive, depending on the nature of the incentive (e.g., cash vs. premium reduction), could also get a better benefit under the self-insured medical plan and/or cafeteria plan which could, in turn, affect nondiscrimination testing. Incentives could affect the benefits test under section 105(h) and the key employee concentration and the benefit and contributions tests under section 125.
As a result of these tax issues, plan sponsors should seek the advice of competent benefits counsel to weigh the pros and cons of the type of incentives to offer, and to decipher potential tax issues.C. Compliance Concerns That May Arise When DM Programs are Integrated With HSAs or HRAsIn light of the tax and VEBA compliance issues associated taxable financial incentives, many employers seek to direct incentives toward tax-free health savings account (HSA) or health reimbursement arrangement (HRA) benefits. As discussed in this section, great care should be exercised to ensure that the applicable operating rules associated with HSA and HRA arrangements are not violated.
1. HSAs and the Comparability Requirement - As employers search for new ways to keep illness and health plan spending down and promote wellness programs, HSAs are often considered. An employer that sponsors an HSA is not required to make HSA contributions. However, if an employer makes HSA contributions, the employer is subject to a 35% excise tax on all of its HSA contributions made during the calendar year unless it “makes available comparable contributions to the [HSAs] of all comparable participating employees for each month during such calendar year.” Generally, if an employer makes contributions to HSAs, it must contribute the same amount or the same percentage of the deductible to all employees who are eligible individuals, and who have the same coverage category (self-only or family). The employer may, however, restrict its contributions to those eligible individuals covered under the employer’s HDHP provided that the employer makes no contributions to any employee not covered under the employer’s HDHP. Also, the test may be run separately for “part-time employees”, which is statutorily defined as those who customarily work fewer than 30 hours per week. We call this the “HSA comparability rule.”Unfortunately, this inflexible “comparability” requirement does not fit well with the goal of rewarding DM Program participants with HSA-based financial incentives for DM participation. However, the HSA comparability rule does not apply when employer contributions (including matching contributions and bonuses for disease management and wellness programs) are “made through a Section 125 cafeteria plan”. IRS Notice 2004-50 includes the following discussion:Q-49. If under the employer’s cafeteria plan, employees who are eligible individuals and who participate in health assessments, disease management programs or wellness programs receive an employer contribution to an HSA, unless the employee elects cash, are the contributions subject to the section 4980G comparability rules?A-49. No. The comparability rules under section 4980G do not apply to employer contributions to an HSA through a cafeteria plan.Employers struggle, however, with this concept of a DM-based HSA contribution being made “through a cafeteria plan.” Exactly when is a contribution considered to be made "through a cafeteria plan?" If the example above is read too literally, it would seem that a “cash” incentive must always be available for the DM incentive to be offered through the cafeteria plan.
2. HRAs and DM IncentivesMany consumer-driven healthcare arrangements include a health reimbursement arrangement (HRA) under which unused funds carry forward into subsequent years. Often plan sponsors seek to include the DM financial incentive as part of the HRA – i.e., participating in the wellness or DM program results in an increased HRA contribution. As discussed below, this plan design may create compliance issues under the current HRA rules.Currently, employer contributions to an HRA may NOT be attributable in whole or part to pre-tax salary reductions made under a cafeteria plan. In addition, an HRA may not be funded with benefit credits that could otherwise be received as cashable compensation. This does not mean that the HRA cannot be offered in conjunction with a major medical plan (e.g., an HDHP) that is funded in part with employee pre-tax contributions. However, the “no direct/indirect” funding requirement must be satisfied in order for the HRA to be offered with a medical plan that is offered under the cafeteria plan – i.e., employee salary reductions (or employer cashable credits) cannot fund the HRA either directly or indirectly.No direct funding of HRA: The first condition is satisfied if employee pre-tax salary reduction amounts do not directly fund the HRA. Direct funding does not occur if (i) the salary reduction agreement indicates that salary reductions are used solely for the non-HRA portion of the major medical plan, and (ii) the employee pre-tax salary reductions for the major medical plan are less than the applicable COBRA premium for such coverage. For example, if the applicable COBRA premium for single major medical coverage is $1,800 per year, the annual salary reduction election for such coverage must be less than $1,800. The applicable COBRA premium is generally the cost to the plan to provide such coverage. The 2% administrative charge permitted by COBRA is in addition to the applicable premium. The salary reduction must be less than the applicable premium for such coverage without consideration of the 2% administrative charge.No indirect funding of HRA: A substantially less clear condition is that the HRA cannot interact with a cafeteria plan in such a way that it is indirectly funded with pre-tax salary reductions. IRS HRA guidance indicates that where an employee who participates in an HRA has a choice among two or more medical plan options to be used in conjunction with the HRA (or a choice among various maximum reimbursement amounts), and there is a correlation between the maximum reimbursement amount under the HRA and the salary reduction election for a specified medical plan, then the salary reduction is attributed to the HRA, even if the salary reduction is less than the applicable COBRA premium. For example, an employer may not permit an employee to choose a higher salary reduction amount for a particular level of specific medical plan coverage in order to receive a higher HRA amount. In the example provided by the IRS HRA guidance, the employer offers family medical coverage worth $4,500. The employee may choose to contribute on a pre-tax salary reduction basis either $2,500 or $3,500 for such coverage. If the employee elects the $2,500 salary reduction option, the employee receives a $1,000 credit to his or her HRA. If the employee elects the $3,500 salary reduction option, he or she will receive a much higher HRA credit of $2,000. The example set forth in the guidance (and discussed above) indicates that an employee cannot have a choice between a higher salary reduction amount and a higher HRA. Thus, it may be permissible to offer multiple medical plan options in conjunction with the HRA provided that HRA reimbursement amounts increase as salary reduction amounts decrease.
For example, assume an employer offers two medical plan options in conjunction with an HRA. Option 1 offers major medical with a $3,000 deductible. The applicable premium for such coverage for the year is $2,000. The required salary reduction amount is $500 and the HRA amount is $2,000.
Alternatively, employees can choose Option 2, which offers a major medical plan with a $4,000 deductible and an applicable premium of $1,500. The salary reduction amount for Option 2 is $300 and the HRA is $3,000. This would appear to be permissible because the employee is not electing a higher salary reduction amount for a higher HRA (it is quite the opposite).The IRS HRA guidance identifies two other situations where the salary reduction is attributable to the HRA, even though the salary reduction amount is less than the applicable COBRA premium. One, an HRA is deemed to be indirectly funded with pre-tax salary reductions if the employee may choose to apply the HRA amount toward the employee’s share of medical plan coverage in lieu of the pre-tax salary reduction. Two, an HRA is deemed to be indirectly funded with pre-tax salary reductions if the amount credited to the HRA is related to an amount forfeited under a Health FSA. Impact of HRA Rules on DM financial incentives: Health plan sponsors must be especially vigilant of the HRA indirect funding rules when designing their DM financial incentive arrangements. For example, an employer that creates a DM health incentive for all employees that participate in a specified disease management or wellness program may run afoul of the HRA indirect funding rule if the DM financial incentive is deposited in an HRA. Consider the following: Wellco currently has two health plan options. A PPO option with an employee contribution rate of $100 per month and a high deductible HRA option with an employee contribution of $200 per month with $100 per month accruing in an HRA. Wellco is considering a DM incentive whereby employees in either option can receive a $10 per month HRA credit for completing a health risk assessment. Are there any issues under the HRA indirect funding rule? Under the above arrangement, it appears that participants have a choice of the Wellco PPO option or HRA option – both of which have a related DM HRA. While the PPO option has a DM HRA, additional HRA contributions can be obtained by electing to salary reduce an additional $100 per month and electing the HRA option (in lieu of the PPO). This could be considered to be a violation of the indirect funding rule. The amount of the HRA accrual for the DM incentive for the PPO option is less than the HRA accrual for the HRA option. Therefore, if the salary reduction amount for the health coverage under the HRA health coverage option is greater than the salary reduction amount for the health coverage offered with the PPO Plan, then there may be an indirect funding issue -- i.e., the HRA accrual increases in tandem with the salary reduction. Arguments can be made that the Wellco plan does not violate the indirect funding rule – e.g., indeed, the DM incentive is equally available regardless of salary reduction contribution amount. However, once this issue is identified, conservative employers may wish to evaluate a couple of alternatives to possibly eliminate the "indirect funding" issue. First, given the nominal amount of the DM HRA, perhaps it could be offered without a carryover -- thus making it an FSA but not an HRA at all. This would facilitate offering the DM incentive without adversely affecting the indirect funding rule. Alternatively, depending on pricing and benefit offerings, if the HRA option has a lower salary reduction requirement than the PPO option, then an indirect funding issue should not arise.Needless to say, great care should be taken in designing a DM incentive program to ensure that the direct/indirect funding rules are not violated.ConclusionWe have examined the ADA, HIPAA nondiscrimination as well as privacy, COBRA, ADEA, and tax issues (HSA and HRA issues) related to DM programs. While DM programs continue to gain popularity and make their mark on the healthcare industry, employers should take care to take a measured approach looking at the whole picture, including the benefits compliance issues associated with such arrangements.
www.unicaresoundplans.com
www.medequote.com
www.medequote.net
Saturday, July 08, 2006
UniCare HSA Plans gaining momentum
The sales of UniCare HSA plans have increased quite a bit this year as the price of competitors products have risen and the UniCare HSA Plan prices have reamined stable as expected.
Say's John Berkowitz of www.medequote.com "The prices for all UniCare products are very stable from year to year, and the best thing about UniCare is they charge the same price to new consumers, as they do to existing plan members, they don't supplement new enrollment by offering a low price initially then raising the price dramatically in the second year."
UniCare offers four different HSA plan options for consumers, and the plans are now available in Illinois, Texas, Michigan, and Virginia.
Sales have been brisk according to Berkowitz, "In the Illinois market, particularly in Chicago there really is only one choice price wise, and that is currently UniCare, but we do sell BCBSIL HSA plans to families who want the maternity option added to their health plan. Assurant also offers the same maternity option with HSA plans."
"We have a lot of consumers from other states who call and ask for UniCare products, or ask when they will be available here, so you know there is quite a national buzz surrounding everything UniCare does", says Berkowitz.
UniCare HSA plans and UniCare HSA Quotes are available at www.medequote.com, and www.medequote.net.
Say's John Berkowitz of www.medequote.com "The prices for all UniCare products are very stable from year to year, and the best thing about UniCare is they charge the same price to new consumers, as they do to existing plan members, they don't supplement new enrollment by offering a low price initially then raising the price dramatically in the second year."
UniCare offers four different HSA plan options for consumers, and the plans are now available in Illinois, Texas, Michigan, and Virginia.
Sales have been brisk according to Berkowitz, "In the Illinois market, particularly in Chicago there really is only one choice price wise, and that is currently UniCare, but we do sell BCBSIL HSA plans to families who want the maternity option added to their health plan. Assurant also offers the same maternity option with HSA plans."
"We have a lot of consumers from other states who call and ask for UniCare products, or ask when they will be available here, so you know there is quite a national buzz surrounding everything UniCare does", says Berkowitz.
UniCare HSA plans and UniCare HSA Quotes are available at www.medequote.com, and www.medequote.net.
Thursday, July 06, 2006
Illinois Student Health Insurance
We have been getting quite a few calls from Illinois residents concerning the UniCare Sound plan and it's use as a Illinois Student health insurance plan.
UniCare Sound is the perfect health insurance plan for Illinois students. The plan provides coverage for Hospital, Surgical, ER, Unlimited Doctor Visits, Prescriptions, Dental and Vision. What get's everyone's attention is the low price per month which ranges between $60 - $114 per month depending on your age, sex, where you live, or are going to school. The price may be low but the coverage isn't compared to so called Illinois Student Health Insurance Plans.
Parents like the UniCare Sound Student plan because it provides a lot more coverage than is typically offered with school policies, and the large network gives nation wide coverage while traveling.
Illinois students like the fact that they are covered head to toe and can visit any emergency room. The unlimited $40 copay for doctor visits means that health care is now affordable when they have a problem. The dental plan pays 100% for checkups, and 80% for fillings! The vision provides for an $50 toward your eyes exam and deep discounts on contacts, and eyewear!
The UniCare Sound plan is the hottest thing to enter the Illinois Health Insurance market in the last decade! The plan is available in three different deductible, $1500, $3000, and $5000. All are 100% plans with out any coinsurance, and no hassles! Your yearly out of pocket for Hospitilization and Surgery equals your yearly deductible, everything else is first dollar coverage!
The application process is simple, apply online, or over the phone, the whole process takes less than 10 minutes, and a healthy person can be covered right away! Just click above to get a Illinois health insurance quote for the UniCare Sound plan. It is the ideal Illinois Student Health Insurance Plan.
www.unicaresoundplans.com
www.medequote.com
UniCare Sound is the perfect health insurance plan for Illinois students. The plan provides coverage for Hospital, Surgical, ER, Unlimited Doctor Visits, Prescriptions, Dental and Vision. What get's everyone's attention is the low price per month which ranges between $60 - $114 per month depending on your age, sex, where you live, or are going to school. The price may be low but the coverage isn't compared to so called Illinois Student Health Insurance Plans.
Parents like the UniCare Sound Student plan because it provides a lot more coverage than is typically offered with school policies, and the large network gives nation wide coverage while traveling.
Illinois students like the fact that they are covered head to toe and can visit any emergency room. The unlimited $40 copay for doctor visits means that health care is now affordable when they have a problem. The dental plan pays 100% for checkups, and 80% for fillings! The vision provides for an $50 toward your eyes exam and deep discounts on contacts, and eyewear!
The UniCare Sound plan is the hottest thing to enter the Illinois Health Insurance market in the last decade! The plan is available in three different deductible, $1500, $3000, and $5000. All are 100% plans with out any coinsurance, and no hassles! Your yearly out of pocket for Hospitilization and Surgery equals your yearly deductible, everything else is first dollar coverage!
The application process is simple, apply online, or over the phone, the whole process takes less than 10 minutes, and a healthy person can be covered right away! Just click above to get a Illinois health insurance quote for the UniCare Sound plan. It is the ideal Illinois Student Health Insurance Plan.
www.unicaresoundplans.com
www.medequote.com
Tuesday, July 04, 2006
Is it OK to call children obese?
Is it OK for doctors and parents to tell children and teens they're fat?
That seems to be at the heart of a debate over whether to replace the fuzzy language favored by the U.S. government with the painful truth. Labeling a child obese might "run the risk of making them angry, making the family angry," but it addresses a serious issue head-on, said Dr. Reginald Washington, a Denver pediatrician and co-chairman of an American Academy of Pediatrics obesity task force."If that same person came into your office and had cancer, or was anemic, or had an ear infection, would we be having the same conversation? There are a thousand reasons why this obesity epidemic is so out of control, and one of them is no one wants to talk about it."
www.medequote.com
www.medequote.net
www.unicaresoundplans.com
That seems to be at the heart of a debate over whether to replace the fuzzy language favored by the U.S. government with the painful truth. Labeling a child obese might "run the risk of making them angry, making the family angry," but it addresses a serious issue head-on, said Dr. Reginald Washington, a Denver pediatrician and co-chairman of an American Academy of Pediatrics obesity task force."If that same person came into your office and had cancer, or was anemic, or had an ear infection, would we be having the same conversation? There are a thousand reasons why this obesity epidemic is so out of control, and one of them is no one wants to talk about it."
www.medequote.com
www.medequote.net
www.unicaresoundplans.com
Subscribe to:
Posts (Atom)