On November 18, 2015 the departments of Treasury, Labor and Health and 
Human services issued final rules regarding many of the affordable care Act "market reforms." Among the issues reforms, departments have highlighted the prohibition annual limit dollar (Public Health Service (section) PHS Act 2711) compared to repayment plans. This article breaks down the language in the notice and how it relates to Zane Benefits Solutions for reimbursement of individual health insurance.
The prohibition annual limit on the dollar prevents health plans to put dollar limits on certain covered benefits. This protection ensures that patients do not face the cost of devastating health care because they have exhausted their health coverage when faced with a serious medical condition. With hindsight, this improvement in health plans unintentionally limited ways an employer can provide certain types of repayment plans.
Although the limited reforms of certain types of repayment plans, the final rules confirm that employers can reimburse employees for individual health insurance premiums and basic prevention services by means of a system of reimbursement of health care (HRP), without infringing the prohibition annual limit on the dollar.
What are the limits of lifetime and annual?
Before the Affordable Care Act, group plans and health insurance issuers have generally been allowed to impose dollar limits on how much the plan would go for health services covered. This could apply throughout the period an individual has been registered in the (limited lifetime) or during a plan year (annual limit). From 1 January 2014, the prohibition of annual dollar limit (PHS Act section 2711) prevents group health plans and health insurance issuers from imposing lifetime and annual dollar limits certain benefits defined as essential health services (FSA).
? What is an essential health benefit (EHB)
essential health services, as defined in Section Affordable Care Act 1302, include the following categories of services and items and services covered in
- ambulatory patient services
- emergency services
- hospital
- maternity and newborn care
- services for mental health and addiction, including the treatment of behavioral health
- prescription drugs
- rehabilitation and adaptation services and devices
- laboratory services
- preventive services and wellness and chronic disease management
- pediatric services, including oral and vision care.
Although the annual dollar limits ban prevents plans impose limits on covered benefits that fall within the definition of EHB, the rules do not prevent plans for placing limits on covered benefits that do not meet the definition of EHB. This allows plans to repay non-EHBs such as individual health insurance premiums without violating the ban on annual limits.
Examples of non-compliance
The final rules define and refer to "account based plans," such as group health plans provided by employers that provide reimbursements other than individual medical premiums market policy with reimbursement subject to a maximum amount fixed in dollars for a period. These plans, including self HRA and employer payment plan, are subject to the prohibition of the annual limit . These arrangements dollar fail to comply with the ACA reforms for two main reasons:
- the maximum amount fixed in dollars for a period puts a limit on covered essential health services, violating the prohibition annual dollar limit (PHS Act section 2711), and
- the maximum amount fixed in dollars for a period may impose limits and cost sharing on some prevention services, violating the obligation to serve preventive (PHS Act section 2713)
How to comply with the prohibition of annual dollar limit?
final rules confirm that employers can use a health care reimbursement scheme (HRP) to reimburse employees for health insurance premiums. HRP is carefully designed to meet the annual ban on dollar limits by only allowing reimbursement of insurance premiums (not a delivery of essential health, therefore not subject to the prohibition annual limit on the dollar), and certain preventive services (Essential Health Benefit reimbursed without limit or cost sharing, thus complying with the prohibition of annual dollar limit and preventive service requirement).
0 Komentar