Monday, June 17, 2019

When is a QSEHRA *not* a QSEHRA?

Regular readers may recall our post last year on the debacle that was Qualified Small Employer Health Reimbursement Arrangements (QSEHRAs):

"Their reaction, once learning about the caveats and limitations, has been a resounding /crickets ... the devil truly is in the details."

In other words: a dud.

But that was then, and this is now:

"The Health and Human Services, Labor and Treasury Departments joined forces on a new initiative intended to provide affordable health careOpens a New Window.  coverage ... The legislation will expand the use health reimbursement arrangements (HRAs), allowing employees use pre-tax health arrangements to buy insurance."

First impressions:

This sounds great on paper (maybe), but what differentiates this new effort from last year's failed version?

I reached out to our gurus of all thing FSA/HRA/HSA for their initial take, asking if this was just a QSEHRA re-hash. They graciously responded that it is not last year's iteration, but a new alphabet soup, almost 500 pages long, with a lot of details. They also pointed out that the original QSEHRA was a flop because of all of the rules, and that this version may be as well.

I would add something else that seems to have slipped under the radar in both instances:

Group plans have participation requirements; that is, a minimum percentage of employees must be on the group plan or it will go away (I've had this happen, and it's not pretty). To be fair, it's not usually enforced that rigidly, but I suspect that would change if carriers saw their groups suddenly shedding participants willy-nilly.

Now, as one who would ultimately like to see health insurance de-coupled from employment, this is not unappealing. But as a realist, I think this is playing a little too close to the edge of the envelope.

And there's this: pretty much all group plans are built on the PPO model (coverage in- and out-of-network). But all of the individual plans I've seen the past two cycles (and I have no reason to think this won't continue to be the case) are HMO's, meaning that there is essentially zero OON coverage.

What's that worth?

Oh, and one more thing: if your employer offers a group plan, then you likely won't qualify for a subsidy on that individual major med. And since ACA plans include pretty much all the things that make group coverage so expensive (guaranteed issue, pre-ex and maternity cover, for example) plus often (usually?) have much higher out-of-pocket limits, not seeing the savings.

Time will tell.

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