Monday, October 30, 2017

**New Proposed Regulations**

On October 27, 2017, the Department of Health and Human Services (HHS) issued proposals which reflect the current administrator’s desire to improve access to plans on the Exchange, increase competition, and reduce some of the premium increases affected by the ACA provisions.
Most notably, the proposal allows states to select a benchmark plan from among these three sources:
  • Choose another state’s 2017 benchmark plan. This allows state’s with a more generous benchmark to choose from among benchmark plans in every state, and apply those benefits to their own state’s plans.
  • Replace one or more EHB categories of benefits under its current 2017 benchmark plan with another state’s benefits of the same category. This allows states to cherry-pick their benefit standards.
  •  Select a new benchmark plan from among a set of ‘typical employer plans’. The new benchmark plan need be no more generous than the most generous of a set of comparison plans. The proposal defines ‘typical employer plan’ as a product with substantial enrollment, with at least 5,000 enrollees, or a self insured group health plan with 5,000 or more enrollees. The state is required to demonstrate the value of each benefit in the benchmark plan by providing an actuarial analysis to the HHS. This specific provision may have the greatest impact on the plans offered through the exchange where states have selected this method of determining their benchmark plans, as many large group and self insured plans provide less of the essential health benefits than those of the state exchanges.
As a reminder, the ACA is still law, and employers are required to deliver 1095 C forms to employees by January 31, 2018. E-filing with the IRS is due by March 31, 2018. Please contact your dedicated service associated for assistance and advice when completing the forms.

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