Enrollment services. Do they really work? How can an employer or their benefits broker weed through all the promises?
Colonial Life puts their money where their mouth is, by offering employees the opportunity to rate the communication, knowledge, and professionalism of our enrollers with a simple online survey.
If you want to know the effectiveness of your benefits communication, let Colonial handle your enrollment and judge the results for yourself.
Wednesday, December 9, 2009
Friday, March 20, 2009
I have moved my blog.
I have moved my blog to Wordpress. Please follow the link and follow my new blog.
Thanks you.
J. Keith Johnson
Thanks you.
J. Keith Johnson
Tuesday, February 24, 2009
The COBRA's Bite or How the Stimulus Bill Will Kill Business
The problem I see in this stimulus bill is the COBRA/state continuation element of the package. Far from stimulating the economy, it will create a tremendous burden for already strapped small business by requiring a 65% participation in COBRA premium, retroactive to last September 1st. (Aren't ex post facto laws unconstitutional? U. S. Constitution, Article 1, Section 9. I know it is in regard to criminal law. I just don't see how any punitive ex post facto law is moral.)
Granted, an employer may offset the premium with a credit against his payroll taxes, but every company I know is looking for income and sales, not costs and credits. In addition, I believe that insurance premiums are paid on a monthly basis, in advance, whereas a payroll tax credit would be quarterly, after the fact. Nice of Congress to create debt for businesses. Of course, they are the experts.
Oh, has anyone examined the effect this payroll tax short fall will create on the Ponzi scheme we call Social Security? Prior to the stimulus bill, we were robbing Peter to pay Paul. Now we're robbing both of them.
This is bad legislation, poorly conceived, poorly written, and soon to be poorly administered.
Granted, an employer may offset the premium with a credit against his payroll taxes, but every company I know is looking for income and sales, not costs and credits. In addition, I believe that insurance premiums are paid on a monthly basis, in advance, whereas a payroll tax credit would be quarterly, after the fact. Nice of Congress to create debt for businesses. Of course, they are the experts.
Oh, has anyone examined the effect this payroll tax short fall will create on the Ponzi scheme we call Social Security? Prior to the stimulus bill, we were robbing Peter to pay Paul. Now we're robbing both of them.
This is bad legislation, poorly conceived, poorly written, and soon to be poorly administered.
Monday, February 16, 2009
New COBRA requirements
This is from benefitsblog...
Late on Friday, the Senate approved the economic stimulus legislation sending the bill to the President for his signature. It is unclear when he will sign the legislation, but his signature is expected this week.
As I indicated last week, the bill contains a number of important COBRA revisions that plan sponsors will need to immediately implement. These provisions are discussed in more detail below. In addition, beginning March 1, 2009, the bill also increases the monthly amount for transit passes to the level allowed for parking, and the bill also makes certain changes with respect to the HIPAA privacy and security rules implemented as part of the health information technology provisions. For those who would like to review the actual language, I have attached Division B of the bill to this email. The COBRA provisions begin on page 396 of the PDF.
The COBRA revisions are effective March 1, 2009. Due to this very short deadline, a conference call has been scheduled for Wednesday between Treasury and the benefits community. We expect that a number of questions will be answered during that call. Due to the importance of Treasury input in this process, we will be distributing our Legal Alert after this call so that we can incorporate the guidance which is expected to flow from that call. With that in mind, the following is a summary of the final COBRA revisions.
COBRA Subsidy
The COBRA premium subsidy applies to involuntary losses of employment between September 1, 2008 and December 31, 2009. Under the subsidy, the qualified beneficiary would pay 35% of the applicable COBRA premium and 65% of the premium would be subsidized by the employer. The employer may then claim the amount of that subsidy as a credit against its payroll taxes. The subsidy would expire after 9 months, leaving the remaining months as unsubsidized. If a second qualifying event occurred during that timeframe, it appears that the qualified beneficiary would be able to continue utilizing the subsidy (e.G., a divorce or death). The bill requires a special 60-day election period for those who are eligible for the subsidy but failed to previously elect COBRA - e.g., an individual who terminated employment in October 2008 and who did not elect COBRA would receive a second chance to enroll currently. Further, the bill allows, but does not require, employers to allow current COBRA participants to switch to any other medical option under the employer’s plan. The COBRA provisions specifically do not apply to health FSAs. Finally, the subsidy starts to phase out for individuals with incomes above $125,000 for single and $250,000 for married couples.
COBRA Expansion
The House version of the bill would have expanded COBRA for those individuals who are at least 55 years old or who have at least 10 years of service. This provision was eliminated by the conference committee, and is not in the final bill.
Preparation for Change
A number of administrative revisions will be needed to implement the new COBRA provisions. These revisions include the following:
1. Employers/COBRA administrators will need to prepare a special enrollment notice and send that notice to all employees who terminated employment since September 1, 2008. These employees could then elect COBRA currently with the premium subsidy. COBRA would continue for the remainder of its original term.
2. Employers/COBRA administrators will need to prepare a special notice to existing COBRA participants informing them of the new premium subsidy and their new premiums going forward, and possibly allowing them the opportunity to change to another medical option offered by the employer. The bill includes a 60-day grace period that allows refunds of previously paid premiums.
3. Administrative procedures will need to be developed to implement all of the changes (e.g., new premium structure, new notices, and calculating the amount of the subsidy actually utilized each month so that the proper amount can be credited against the employer’s payroll taxes). In addition, the subsidy only applies to involuntary terminations. Failure of employers to properly identify those who are eligible for the subsidy will mean that the employer’s payroll taxes are unpaid, potentially subjecting employers to underpayment penalties.
4. Additional notices will need to be developed to inform COBRA participants when they reach the maximum subsidy limit.
5. Additional procedures and notices will need to be developed to allow high income enrollees to opt out of the subsidy. An attestation process is included in the final bill.
6. The existing COBRA initial notice and election notice will need to be modified to include the new subsidy rules on a going forward basis.
Some of these issues should be become clearer after the Treasury conference call on Wednesday. We will incorporate the Treasury guidance in our Legal Alert that will be sent later this week. If you have any questions, please feel free to contact me.
recovery_bill_div_b
Mark L. Stember
Kilpatrick Stockton LLPSuite 900607 14th Street, NWWashington, DC 20005t 202.508.5802f 202.585.0018
[?]
Late on Friday, the Senate approved the economic stimulus legislation sending the bill to the President for his signature. It is unclear when he will sign the legislation, but his signature is expected this week.
As I indicated last week, the bill contains a number of important COBRA revisions that plan sponsors will need to immediately implement. These provisions are discussed in more detail below. In addition, beginning March 1, 2009, the bill also increases the monthly amount for transit passes to the level allowed for parking, and the bill also makes certain changes with respect to the HIPAA privacy and security rules implemented as part of the health information technology provisions. For those who would like to review the actual language, I have attached Division B of the bill to this email. The COBRA provisions begin on page 396 of the PDF.
The COBRA revisions are effective March 1, 2009. Due to this very short deadline, a conference call has been scheduled for Wednesday between Treasury and the benefits community. We expect that a number of questions will be answered during that call. Due to the importance of Treasury input in this process, we will be distributing our Legal Alert after this call so that we can incorporate the guidance which is expected to flow from that call. With that in mind, the following is a summary of the final COBRA revisions.
COBRA Subsidy
The COBRA premium subsidy applies to involuntary losses of employment between September 1, 2008 and December 31, 2009. Under the subsidy, the qualified beneficiary would pay 35% of the applicable COBRA premium and 65% of the premium would be subsidized by the employer. The employer may then claim the amount of that subsidy as a credit against its payroll taxes. The subsidy would expire after 9 months, leaving the remaining months as unsubsidized. If a second qualifying event occurred during that timeframe, it appears that the qualified beneficiary would be able to continue utilizing the subsidy (e.G., a divorce or death). The bill requires a special 60-day election period for those who are eligible for the subsidy but failed to previously elect COBRA - e.g., an individual who terminated employment in October 2008 and who did not elect COBRA would receive a second chance to enroll currently. Further, the bill allows, but does not require, employers to allow current COBRA participants to switch to any other medical option under the employer’s plan. The COBRA provisions specifically do not apply to health FSAs. Finally, the subsidy starts to phase out for individuals with incomes above $125,000 for single and $250,000 for married couples.
COBRA Expansion
The House version of the bill would have expanded COBRA for those individuals who are at least 55 years old or who have at least 10 years of service. This provision was eliminated by the conference committee, and is not in the final bill.
Preparation for Change
A number of administrative revisions will be needed to implement the new COBRA provisions. These revisions include the following:
1. Employers/COBRA administrators will need to prepare a special enrollment notice and send that notice to all employees who terminated employment since September 1, 2008. These employees could then elect COBRA currently with the premium subsidy. COBRA would continue for the remainder of its original term.
2. Employers/COBRA administrators will need to prepare a special notice to existing COBRA participants informing them of the new premium subsidy and their new premiums going forward, and possibly allowing them the opportunity to change to another medical option offered by the employer. The bill includes a 60-day grace period that allows refunds of previously paid premiums.
3. Administrative procedures will need to be developed to implement all of the changes (e.g., new premium structure, new notices, and calculating the amount of the subsidy actually utilized each month so that the proper amount can be credited against the employer’s payroll taxes). In addition, the subsidy only applies to involuntary terminations. Failure of employers to properly identify those who are eligible for the subsidy will mean that the employer’s payroll taxes are unpaid, potentially subjecting employers to underpayment penalties.
4. Additional notices will need to be developed to inform COBRA participants when they reach the maximum subsidy limit.
5. Additional procedures and notices will need to be developed to allow high income enrollees to opt out of the subsidy. An attestation process is included in the final bill.
6. The existing COBRA initial notice and election notice will need to be modified to include the new subsidy rules on a going forward basis.
Some of these issues should be become clearer after the Treasury conference call on Wednesday. We will incorporate the Treasury guidance in our Legal Alert that will be sent later this week. If you have any questions, please feel free to contact me.
recovery_bill_div_b
Mark L. Stember
Kilpatrick Stockton LLPSuite 900607 14th Street, NWWashington, DC 20005t 202.508.5802f 202.585.0018
[?]
Monday, February 9, 2009
Why Is Health Care So Expensive?
Watch this link for an idea on why healthcare is so expensive and what we can do to control it.
http://www.youtube.com/watch?v=JYC2DJWU41s
http://www.youtube.com/watch?v=JYC2DJWU41s
Saturday, February 7, 2009
New Creation Story
This link should take you to a tongue in cheek take on creation and health insurance.
Enjoy.
http://docs.google.com/Presentation?id=d3z83ct_13d7jj5cg4
Enjoy.
http://docs.google.com/Presentation?id=d3z83ct_13d7jj5cg4
Monday, February 2, 2009
Rising Cost of Insurance
http://docs.google.com/Presentation?id=dfk9fpgn_5gv7j35dn
This link will take you to a Google document presentation by Partners Insurance out of Arkansas. Please note the focus is on wellness and claims errors.
I believe that a shift to the consumer driven/one deductible plans will encourage the insured to monitor their costs and their bills. Once we take the waste out of the health delivery system we can start to control costs and, therefore, premium.
This link will take you to a Google document presentation by Partners Insurance out of Arkansas. Please note the focus is on wellness and claims errors.
I believe that a shift to the consumer driven/one deductible plans will encourage the insured to monitor their costs and their bills. Once we take the waste out of the health delivery system we can start to control costs and, therefore, premium.
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