Friday, July 27, 2018

Good Intentions, Awful Execution

So to all the alphabet soup that is modern American heath care, we can add QSEHRA (Qualified Small Employer Health Reimbursement Arrangement):

"This new legislation specifically "enable[s] small employers with fewer than 50 full-time employees to fund qualified stand-alone HRAs. Employees may use the HRA to pay for qualified out-of-pocket medical expenses, including individual polices purchased through the public exchanges."

So far, so good: I've long been a big fan of the "defined contribution" model. That is, instead of a "one size fits all" small group health insurance plan, employees are given a budget to pay for a plan of their own choosing (or forgo a plan altogether). Call it a "health insurance gift card" that's good both on- and off-Exchange.

What's not to love, right?

So, I reached out to our gurus of all things Alphabet Soup (HSA, HRA, etc) for their take.

Turns out, they've been offering to help set these up for a while now, going so far as to sponsor Continuing Education classes for agents to help sell the concept to their small group clients. The response from agents was tremendous: a great deal of enthusiasm both for the free CE and the plans themselves. Which is fine, but far from the most important metric: what about their clients?

Their reaction, once learning about the caveats and limitations, has been a resounding /crickets.

But why is that? After all, it only takes a pretty simple (and inexpensive) set of documents to be up and running, and then each employee can go choose whatever plan best suits him or her (or, again, none at all).

Aye, there's the rub: yes, the setting one up part is pretty low-cost and straightforward, but the devil truly is in the details. For one thing, there are all kinds of non-discrimination rules (for example, one can't give managers more than those they manage), and you can't have any group-type plan at all (like dental or vision) in place. Even though these are what we call "non-medical," if they're group you're outta luck. And there are other speedbumps, as well. From our gurus:

"When we receive calls inquiring about the QSEHRA plans, we explain to the employer that it is like peeling back the layers of an onion to determine if they meet the requirements to offer the QSEHRA.  Below are the peels that we go through that usually become the challenges:
• They are a subsidiary of another company.

• Corporation Type:  Sole proprietors, partners within a partnership, owners of an LLC (filing as a S or partnership), owners of an LLP and more than 2% owners of an S Corporation are prohibited from participating in the plan and the rules of attribution apply to more than 2% S Owners, thus owner’s spouses, parents, children and grandparents cannot participate. – In the majority of the calls the corporation type is what puts a “STOP” in the peeling process.

• They offer some type of other group plan including dental and/or vision.  Even if it is voluntary it disqualifies them from being eligible to offer the QSEHRA.

• If they are considering offering the QSEHRA to include eligible out-of-pocket medical expenses, they are surprised and often not thrilled that they have to offer it to all employees (even those on spouses plan).

• Impact on the subsidies if an employees is receiving a subsidy of tax credit.  Many employers who contact us have employees with plans that do receive the subsidy of tax credit."
So what happens is that the initial enthusiasm gives way to reality, and thus very few (if, indeed, any) of these actually get implemented. Which is a shame, since the concept holds such promise.

Leave it to the DC Rocket Surgeons to mess up a (potentially) good thing.

Oh! One more thing: it seems that neither DPC fees nor Sharing Ministry "dues" are QSEHRA-eligible since they don't include Minimum Essential Coverage (MEC) requirements (list of acceptable individual plans here). Which is a bummer, since both are otherwise ACA-compliant (just like on- and off-Exchange plans are).
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