Introduction
Several Frequently Asked Questions (FAQs) about applying the affordable health insurance market reform provisions are included below. The Treasury, Labor, and Health and Human Services Departments worked together to create them. These FAQs address stakeholders’ concerns to aid the public in comprehending the new law and reaping its intended benefits.
FAQs About Affordable Health Insurance
Question 1: My plan gives you the choice of three benefit packages: an HMO, a POS agreement, or a PPO. Does giving up grandfather status for the HMO also require giving up grandfather status for the PPO and POS plan?
Answer: The grandfather analysis applies to each benefit package separately. In this case, it is acceptable to consider the PPO, POS agreement, and HMO as different benefits packages. As a result, if one benefit package loses its grandfather status, the other benefit packages’ grandfather status is unaffected.
Question 2:What happens if my dental benefits are set up as HIPAA-exempt benefits? Does the exception mean that the affordable health insurance market reforms do not apply to my dental plan?
Answer: Yes. The rules of the affordable health insurance market reforms do not apply if the benefits qualify as HIPAA-exempt benefits. Dental benefits are often considered exempted benefits under HIPAA if they:
Are provided through a different insurance policy, certificate, or contract; or Are not a fundamental component of the plan. Participants must have the option to decline the coverage and must pay an additional premium if they decide to take it up. Only then will dental benefits, whether insured or self-insured, be deemed to be an optional benefit.
The dental benefits would therefore be excepted benefits, and the market reform provisions would not apply to that coverage if a plan offers its dental benefits as a result of a separate election by a participant and the program requires even a small employee contribution towards the range.
Question 3:The scope, setting, or frequency of the items or services to be covered are not always specified in the recommendations and guidelines issued by the United States Preventive Services Task Force, the Advisory Committee on Immunization Practices of the Centers for Disease Control and Prevention, and the Health Resources and Services Administration. What should my plan do if someone asks for daily dietary counseling?
Answer: The plan or issuer may use reasonable medical management techniques if a recommendation or guideline for a recommended preventive health service does not specify the frequency, method, treatment, or setting for the provision of that service following the interim final regulations on preventive health services.
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Question 4: Can a group health plan (or health insurance provider supplying coverage in connection with a group health plan) provide COVID-19 immunization recipients with a reduction on their monthly premium?
Answer: Yes provided that the premium reduction complies with the wellness program’s final rules.
The five requirements for activity-only wellness programs are listed in paragraph (f)(3) of the final wellness program regulations and apply to premium discounts that require an individual to perform or complete an activity related to a health factor, in this case, receiving a COVID-19 vaccination, to receive a reward.
11 A wellness program that offers a premium reduction to those who receive a COVID-19 immunization must be reasonably created to promote to meet these requirements.
Regarding the employer shared responsibility payment under section 4980H (b) of the Code, how are premium reductions and surcharges for obtaining or not receiving the COVID-19 immunization, respectively, evaluated to evaluate the affordability of coverage?
When calculating whether employer-sponsored health insurance is cheap, wellness incentives connected to receiving COVID-19 immunizations are classified as not earned. On the other hand, if a person pays a higher premium for health insurance through a COVID-19 vaccine wellness program.
Question 5: Can a group health plan or health insurance provider require vaccinations before granting participants, beneficiaries, or enrollees access to benefits or coverage for otherwise covered goods or services to treat COVID-19?
Answer: No. The PHS Act section 2705, ERISA section 702, Code section 9802, and the Departments’ implementing rules forbid plans and issuers from treating beneficiaries, enrollees, and participants differently in terms of eligibility, premiums, or contributions based on their health.
Conclusion
Some frequently asked questions (FAQs) on implementing affordable health insurance are the Health Insurance Portability and Accountability Act of 1996 and the Coronavirus Aid, Relief, and Economic Security Act. The Departments of Labor, Health and Human Services, and the Treasury collaborated to create these FAQs.
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