AssuredPartners Webinar | SHRM Pre-Approved – Substance Abuse Treatment: Fraud, Abuses, and Other Barriers to Effective Care
Posted May 18, 2018 by Megan DiMartino
The ACA, Mental Health Parity and opioid epidemic have created a “perfect storm” in the substance abuse treatment field. Prior to these legislative changes, many plans had very low financial exposure, limiting the number of treatment days/visits available per year, or even in a lifetime. Today’s reality is that substance abuse treatment facilities are growing rapidly with more direct to consumer marketing of their “luxury, resort-like” amenities. With treatment episodes exceeding six figures, substance abuse is no longer an area of low risk exposure.
Please join AssuredPartners and our speaker, Judi Braswell, LPC, CEAP, GBS, Vice President, Business Development at Behavioral Health Systems, for this SHRM* pre-approved, complimentary, one-hour webinar as she shares insights into the legal landscape related to fraud and abuse and what employers can do to protect their employees. Specifically, this webinar will provide the following:
- Overview of fraud/abuse/low value care
- Substance abuse treatment
- Drug testing
- Claims analysis insights
- Key elements in effective treatment
- Employer strategies/plan design for improving outcomes/ROI
- Thursday, May 31, 2018
- 2:00pm – 3:00pm EDT
- No cost to attend
- This webinar is open to all HR and Finance Professionals – but not to brokers, agents, TPAs and PEOs
For more information contact firstname.lastname@example.org. The information contained in this post, and any attachments, is not intended and should not be misconstrued as legal advice. You should contact your employment, benefits or ERISA attorney for legal direction.
Posted May 14, 2018 by Patrick Haynes
With IRS Rev. Proc. 2018-30, the IRS provided several new increases to various categories that Individuals and Families may elect into a Health Savings Account (HSA) if they have a compatible HDHP (High Deductible Health Plan).
For 2019, the annual contribution limitation for a person with self-only coverage under a high-deductible health plan is $3,500, up from $3,450 in calendar year 2018.
The annual limit on deductible contributions for a person with family coverage under a high-deductible health plan will increase by $100 – from $6,900 in 2018 to $7,000 in 2019.
According to the IRS, a HDHP (High-Deductible Health Plan) is defined under Section 223(c)(2)(A) as a health plan with an annual deductible that is “not less than $1,350 for self-only coverage or $2,700 for family coverage.” Those amounts remain unchanged from 2018’s minimum levels.
Annual out-of-pocket expenses (OOPMAXes) – such as deductibles, copayments, and other amounts that do not include premiums – will have a maximum limit of $6,750 for individuals and $13,500 for families, which also increased from 2018’s limits.
- AP Benefit Advisors’ Multi-Year-HSA-limit-chart (1 page)
- APBA’s FSA/HSA/HRA overview (4 pages)
- IRS Revenue Procedure 2018-30
Posted May 7, 2018 by Megan DiMartino
Healthcare Reform Timeline – Perpetual timeline of all healthcare reform updates from 2010 to 2020 (and 2022-when the Cadillac Tax is scheduled to “begin”).
Consumer-Driven Healthcare Options – Medical Savings Account (MSA), Health Savings Account (HSA), Flexible Savings Account (FSA) and Health Reimbursement Arrangement (HRA) – descriptions, details, pros and cons of each plan type, annual account minimums and maximums, etc.
Consumer-Driven Healthcare Options Chart – Comparison chart between HSAs, MSAs, HRAs and FSAs – same as above, but a single-page reference chart.
PCORI/CERF Fees Schedule – Patient-Centered Outcomes Research Institute (PCORI) Fees and Comparative Effectiveness Research Fees (CERF) schedule through 2020. These fees are due/payable each July via IRS Form 720. For additional background details, please read this. (e.g., Do I owe $2.26 per covered life or $2.39?).
If you have any questions or concerns, please contact your Account Manager or Sales Executive.
For more information, contact email@example.com. The information contained in this post, and any attachments, is not intended and should not be misconstrued as legal advice. You should contact your employment, benefits or ERISA attorney for legal direction.
Posted May 2, 2018 by Patrick Haynes
Mental Health Parity and Addiction Equity Act Guidance Issued by Departments
In an effort to encourage compliance with the MHPAEA (Mental Health Parity and Addiction Equity Act), the departments (DOL, HHS and Treasury) released a regulatory package that includes examples of mental health parity violations, as well as a new disclosure template used to request documentation from an employer-sponsored health plan or an insurer regarding treatment limitations. They are also enforcing civil monetary penalties for parity violations.
The Mental Health Parity and Addiction Equity Act of 2008 prevents group health plans from providing mental health and substance use disorder (MH/SUD) benefits, financial requirements, or nonquantitative treatment limitations (NQTL) that are more limiting or not as favorable than those benefits, financial requirements, or NQTLs provided for medical/surgical benefits. (Simple violations can occur when you have a $30 copay on an MH/SUD treatment, but a medical/surgical visit has a $20 copay. Or, when a pre-authoriziation requirement is applied to MH/SUD benefits and not to similar medical/surgical benefits).
Disclosure requirements were set in regulations published in 2013, and were intended to help participants and beneficiaries evaluate MH/SUD parity. In 2016, the Departments of Labor, Treasury, and Health and Human Services (the departments) thought to develop template forms for participants and beneficiaries to use to request information on NQTLs. In 2017, the departments made clear that treatment for eating disorders is classified as a mental health benefits, and requested comments on the disclosures.
According to current regulations, no civil monetary penalties are given for MHPAEA violations, but penalties do include requiring reimbursement or coverage of the inappropriately denied claim, called “equitable relief”.
A new package of guidance was released by the departments on April 23, 2018, and included tools such as FAQs , Pathways to Full Parity (DOL’s 2018 report to Congress), a self-compliance tool, disclosure template, and an action plan from the HHS and fact sheet to help enforce the regulations. The package explains the departments’ ideas that to enforce the MHPAEA more successfully, civil enforcement penalties should be implemented.
The proposed FAQs include examples of specific treatments that the plan cannot deny. For example, the plan could not deny experimental Applied Behavior Analysis therapy claims for a child with Autism Spectrum Disorder that is a professionally recognized treatment, while approving professionally recognized medical/surgical treatments. The plan could also not deny out-of-network inpatient treatment for eating disorders when it would cover a similar treatment for medical/surgical conditions with proper physician authorization.
The Pathways to Full Parity report describes the implementation and enforcement of the MHPAEA, as well as some pilot programs designed by the DOL such as the Regional Opioid Investigative Task Force and Specialized MHPAEA teams (see page 15 of the report here), whose purpose is to further enforce the Act.
The Self-Compliance Tool gives group health plans, plan sponsors, plan administrators, and insurers information to allow them to determine whether a group health plan or insurer complies with the act, and encourages the focus on strategies for compliance rather than the overall result.
The HHS Action plan describes the plan to identify and take action on improper restrictions and the enforcement of compliance for group health plans.
The revised model disclosure form includes changes based on feedback from stakeholders, such as more examples of the standards used to identify NQTLs. Some examples of those standards are excessive utilization two standard deviation above average, and cost escalation of 10% or more per year for 2 years.
Comments on the FAQs are welcome and are due by June 22, 2018.
If you have any questions specific to your plans, please contact your Account Manager or Sales Executive. Thank you.
- May 2, 2016 – Updates from the IRS, DOL and HHS – 2017 HSA Limits and More. Agencies Provide Guidance on Preventive Services, Rescissions, Mental Health Parity, and More
- July 10, 2014 – Effective Dates Have Arrived! Your Wellness Plan and Mental Health Coverages Must Comply
New Guidance links (4/23/2018):
Procedure for sharing comments with the Departments:
Please send comments on these disclosure issues to: Office of Information and Regulatory Affairs, Attn: OMB Desk Officer for DOL-EBSA, Office of Management and Budget, Room 10235, 725 17th Street, N.W., Washington, DC 20503; by Fax: 202-395-5806 (this is not a toll-free number); or by email: OIRA_submission@omb.eop.gov. Commenters are encouraged, but not required, to send a courtesy copy of any comments by mail or courier to the U.S. Department of Labor-OASAM, Office of the Chief Information Officer, Attn: Departmental Information Compliance Management Program, Room N1301, 200 Constitution Avenue, N.W., Washington, D.C. 20210; or by email: DOL_PRA_PUBLIC@dol.gov. Commenters should submit their views by June 22, 2018 to ensure consideration. Comments should reference control number 1210-0138.
For more information, contact firstname.lastname@example.org. The information contained in this post, and any attachments, is not intended and should not be misconstrued as legal advice. You should contact your employment, benefits, or ERISA attorney for legal direction.