Members Will Be Reimbursed for Most Over-the-Counter COVID-19 Diagnostic Tests

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A recent announcement from the federal government intends to increase access to COVID-19 testing. As of January 15, 2022, members can get reimbursed by their health plan without cost share for the costs of over-the-counter diagnostic COVID-19 tests until the end of the Coronavirus Public Health Emergency. Diagnostic tests are performed if members are experiencing COVID-19 symptoms or have been recently exposed. All of the medical carriers are required to participate and we have provided a piece below that gives some preliminary information from each carrier. As more details are released we will continue to update the grid. Please review the Q&A from each carrier to learn about items specific to that carrier in the reimbursement program.

Some cautionary points on the directive:

  1. Reimbursement will only apply to tests purchased after January 15, 2022, validated on your receipt submitted for reimbursement.
  2. Medicare, Medicaid members should contact their carriers as this program may not apply to their coverage.
  3. If OTC tests come in a package of 2, this will count as 2 of the 8 tests available per person for monthly reimbursement.
  4. No prescription is necessary to obtain testing supplies or to receive reimbursement.

Every home in the U.S. is eligible to order 4 free at-⁠home COVID-⁠19 tests. The tests are completely free. Orders will usually ship in 7-12 days. Click here to order your tests now so you have them when you need them.

Most Recent Carrier Guidance

Contact your Cornerstone representative with any questions.

Insurance Companies and Group Health Plans Now Required to Cover Costs of At-Home COVID-19 Tests

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The following information was originally posted by CMS.gov.

As part of its ongoing efforts across many channels to expand Americans’ access to free testing, the Biden-Harris Administration is requiring insurance companies and group health plans to cover the cost of over-the-counter, at-home COVID-19 tests, so people with private health coverage can get them for free starting January 15th. The new coverage requirement means that most consumers with private health coverage can go online or to a pharmacy or store, buy a test, and either get it paid for up front by their health plan, or get reimbursed for the cost by submitting a claim to their plan. This requirement incentivizes insurers to cover these costs up front and ensures individuals do not need an order from their health care provider to access these tests for free.

Beginning January 15, 2022, individuals with private health insurance coverage or covered by a group health plan who purchase an over-the-counter COVID-19 diagnostic test authorized, cleared, or approved by the U.S. Food and Drug Administration (FDA) will be able to have those test costs covered by their plan or insurance. Insurance companies and health plans are required to cover 8 free over-the-counter at-home tests per covered individual per month. That means a family of four, all on the same plan, would be able to get up to 32 of these tests covered by their health plan per month. There is no limit on the number of tests, including at-home tests, that are covered if ordered or administered by a health care provider following an individualized clinical assessment, including for those who may need them due to underlying medical conditions.

“Under President Biden’s leadership, we are requiring insurers and group health plans to make tests free for millions of Americans. This is all part of our overall strategy to ramp-up access to easy-to-use, at-home tests at no cost,” said HHS Secretary Xavier Becerra. “Since we took office, we have more than tripled the number of sites where people can get COVID-19 tests for free, and we’re also purchasing half a billion at-home, rapid tests to send for free to Americans who need them. By requiring private health plans to cover people’s at-home tests, we are further expanding Americans’ ability to get tests for free when they need them.”

Over-the-counter test purchases will be covered in the commercial market without the need for a health care provider’s order or individualized clinical assessment, and without any cost-sharing requirements such as deductibles, co-payments or coinsurance, prior authorization, or other medical management requirements.

As part of the requirement, the Administration is incentivizing insurers and group health plans to set up programs that allow people to get the over-the-counter tests directly through preferred pharmacies, retailers or other entities with no out-of-pocket costs. Insurers and plans would cover the costs upfront, eliminating the need for consumers to submit a claim for reimbursement. When plans and insurers make tests available for upfront coverage through preferred pharmacies or retailers, they are still required to reimburse tests purchased by consumers outside of that network, at a rate of up to $12 per individual test (or the cost of the test, if less than $12). For example, if an individual has a plan that offers direct coverage through their preferred pharmacy but that individual instead purchases tests through an online retailer, the plan is still required to reimburse them up to $12 per individual test. Consumers can find out more information from their plan about how their plan or insurer will cover over-the-counter tests.

“Testing is critically important to help reduce the spread of COVID-19, as well as to quickly diagnose COVID-19 so that it can be effectively treated. Today’s action further removes financial barriers and expands access to COVID-19 tests for millions of people,” said CMS Administrator Chiquita Brooks-LaSure.

State Medicaid and Children’s Health Insurance Program (CHIP) programs are currently required to cover FDA-authorized at-home COVID-19 tests without cost-sharing. In 2021, the Biden-Harris Administration issued guidance explaining that State Medicaid and Children’s Health Insurance Program (CHIP) programs must cover all types of FDA-authorized COVID-19 tests without cost sharing under CMS’s interpretation of the American Rescue Plan Act of 2019 (ARP). Medicare pays for COVID-19 diagnostic tests performed by a laboratory, such as PCR and antigen tests, with no beneficiary cost sharing when the test is ordered by a physician, non-physician practitioner, pharmacist, or other authorized health care professional. People enrolled in a Medicare Advantage plan should check with their plan to see if their plan offers coverage and payment for at-home over-the-counter COVID-19 tests.

This effort is in addition to a number of actions the Biden Administration is taking to expand access to testing for all Americans. The U.S. Department of Health and Human Services (HHS) is providing up to 50 million free, at-home tests to community health centers and Medicare-certified health clinics for distribution at no cost to patients and community members. The program is intended to ensure COVID-19 tests are made available to populations and settings in need of testing. HHS also has established more than 10,000 free community-based pharmacy testing sites around the country. To respond to the Omicron surge, HHS and FEMA are creating surge testing sites in states across the nation.

Contact your Cornerstone representative with any questions.

Direct and Indirect Compensation Transparency Requirements for Your Group Health Plans

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In response to the Consolidated Appropriations Act of 2021 (CAA) enacted by Congress in December 2020, brokers are now required to disclose compensation amounts if they reasonably expect to receive $1,000 or more in compensation, whether direct or indirect, for their services. This includes all revenue related to brokerage services and/or consulting services for all medical, dental, and vision group health plans of all sizes. These regulations are subject to change in the future upon release of further regulations, but this is the information we have thus far.

This law applies to contracts that are executed or renewed on or after December 27, 2021. This means, if you close your renewals by December 27, you will not have to disclose compensation for 2021. You would, instead, start disclosing compensation with February 1, 2022, groups.

This law also applies to individual market coverage (including student health insurance), however, the interim regulations have put the disclosure responsibility on the carriers.

The description of the compensation can be expressed in multiple ways in the fee disclosure. This means, because most commission scales from the carrier are on a per employee per month (PEPM) basis, you can disclose the PEPM, percentage of premium compensation, or you can choose to disclose the total annual compensation.

As a result of this law, brokers must provide a contract or consulting agreement that includes the following information:

  • A description of the services to be provided by the agent, including:
    • Enrollment
    • Renewal
    • Human Resources
    • Account management
    • Compliance
    • Consulting
  • A description of all direct and indirect compensation

So, What Now?

Cornerstone has provided disclosure and engagement letter templates for your benefit to ensure the communications with your clients are as seamless as possible.

Here are your next steps:

  1. Comprise a list of all your active groups for medical, dental, and vision sales, regardless of size.
  2. Gather your most recent commission statements. Medical and ancillary commissions for Anthem KY, Anthem IN and Humana can be found on the AGB broker commission portal. Statements for medical and ancillary lines from all other Cornerstone carrier partners have been provided to you directly by the carriers, including Aetna, Anthem OH, Humana, Medical Mutual of Ohio, and UnitedHealthcare.
  3. Select one of the two available disclosures and use the template letter to disclose compensation amounts for each
    1. Template broker compensation letter
    2. Disclosure option 1 (provided by NAHU and Cornerstone)
    3. Disclosure option 2
  4. Email the disclosure to each of your groups’ primary contacts.
  5. Repeat annually with each client or as compensations changes due to carrier moves throughout the year.

Please note on the disclosures that it is suggested that you obtain your client’s signature acknowledging receipt of this information. For January 1, 2022, renewals completed before December 27, it is recommended that you follow up with an email from your client to acknowledge the renewal is finalized. Contact your Cornerstone broker advisor with any questions you might have about this new law and the requirements.

Employer Action Required! Distribute Medicare Part D Notices by October 15, 2021

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Group health plan sponsors must provide Medicare Part D “creditable coverage” notices prior to October 15th, the start date of the Medicare annual enrollment period for Part D, Prescription Drug coverage. (The enrollment period is October 15–December 7.) Most plan sponsors use the Model Medicare Part D Notices provided by the Centers for Medicare and Medicaid Services (CMS) to notify affected plan participants. Links to all the model letters (in English and Spanish) are available here.  These notices are in .pdf format.  Cornerstone has provided versions of the notice in Word Document format for your convenience. The carriers plan listings and/or links to their creditable coverage site are available below:

Aetna

Reach out to your broker advisor.

Anthem IN

Coming soon…

Anthem KY

Anthem OH

Humana

Medical Mutual

UHC

  • UHC Creditable Coverage List
  • All Alternate Funded prescription plans are creditable for Medicare except for:

    Year

    Plans

    2015

    		 HP5000 and HE5000

    2016

    		 HP6350, HE6350, HP5000i80, and HE5000i80

    2017

    		 HP5000i80, and HE5000i80

    2018

    		 HP6650 and HE6650

    2019

    		 HP6350, HE6350, HE50003060, HP6650, HE6650, HP50003060Ess,  HE50003060Ess, HP6650Ess. HE6650Ess, NavHE50003060, NavHE6650, NavHE50003060Ess, NavHE6650Ess, CharHE50003060, CharHE6650, CharHE50003060Ess, CharHE6650Ess

    2020

    		 All plans for 2020 are creditable for Medicare Part D.

    2021

    		 All plans for 2021 are creditable for Medicare Part D.

The October 15th deadline applies for all group health plan sponsors, regardless of plan year, plan size, employer size, grandfather status, or whether the plan is insured or self-funded.

Employers who send out Open Enrollment packets prior to October 15th often include the Medicare Part D notices in the Open Enrollment packets, to avoid the extra cost and administrative burden of sending them separately.

Employers are also required to notify CMS online annually that they have sent out these Part D notices. The notice to CMS is due within 60 days after the start of the plan year. See the last paragraph of this article for details.

When Is the Medicare Part D Notice Required?

Medicare Part D notices must be provided at least once annually, prior to October 15th, which is the beginning of the Part D annual enrollment period. Additional notices must be provided if the employer-provided coverage changes (from creditable to non-creditable, or vice-versa), if the individual requests a copy of the notice, and when an individual first enrolls in the employer plan.

Why is the Part D Notice Required?

The reason plan sponsors are required to provide Part D Notices is because a penalty will be imposed on an individual if he/she, after becoming eligible for Medicare Part D coverage, has a lapse of “creditable” prescription drug coverage for a period of at least 63 days. Additionally, such individuals may have to wait until the following October to join. An individual can elect either Medicare prescription drug coverage or other “creditable coverage” to avoid having a lapse in coverage. Thus, Medicare-eligible participants in employer group health plans must know whether or not the employer group coverage is “creditable” so they do not unwittingly incur a late enrollment penalty.

Additional Details on the Disclosure Requirements

  • Group health plan sponsors to whom this disclosure requirement applies include employers and Unions; multiple employer welfare arrangements (MEWAs); federal, state and local government employers; and churches.
  • The Part D Notice must be provided not only to Medicare-eligible active working employees and their dependents, but also to participants who are retired, on COBRA, or disabled and covered under the employer’s prescription drug plan.
  • Although the requirement is only that “Medicare-eligible” individuals be provided this notice, employers often provide it to all plan participants and dependents, because of the practical difficulty of knowing who is Medicare-eligible.

Annual Notice to CMS Also required, though not by October 15th

Additionally, plan sponsors are required to notify CMS annually, via the CMS website (Online Disclosure to CMS form). This notice must be made within 60 days after the beginning of the plan year (or contract renewal date, for small plans that do not file Form 5500s so do not specify a plan year), and it pertains to the creditable coverage status for the prior plan year. For calendar year plans, this notice must be provided to CMS no later than March 1.  Sponsors of non-calendar year plans should mark their calendars to make sure the disclosure to CMS is made within 60 days after the beginning of the plan year. (E.g., for an April 1 plan year, the CMS online disclosure should be made no later than May 30.)

Additionally, if applicable, plan sponsors must complete the Online Disclosure to CMS Form within 30 days after termination of a prescription drug plan or within 30 days after any change in creditable coverage status.

For additional information, click here for the main CMS webpage that provides guidance on “creditable coverage.” Or you can visit the webpage  at https://www.cms.gov/Medicare/Prescription-Drug-Coverage/CreditableCoverage/)

ATTENTION: Plan Year 2022 Registration and Training is LIVE

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It’s that time of the year again! If you completed the registration and training for plan year 2021, the 2022 Marketplace registration and training is now available.

If you did NOT complete last year’s training, the 2022 training is not yet available. You will have the option to enroll in the full training, if desired, once it is available. CMS will conduct additional outreach to let you know when the full training for Plan Year 2022 is available.

If you are a returning agent or broker, follow these steps to complete registration and training:

  1. Log in to the CMS Enterprise Portal
  2. Update your information on your Marketplace Learning Management System (MLMS) agent/broker profile
  3. Complete the Marketplace training requirement
  4. Read and accept the applicable Marketplace Agreement(s)
  5. Print your 2022 Registration Completion Certificate
  6. Confirm your registration by using the Registration Completion List

Throughout the registration process, you can use the Marketplace Registration Tracker to track your progress.

You’re eligible to complete a shorter training. As a returning agent or broker, you will be automatically enrolled in the Marketplace Training for Returning Agents and Brokers, a shorter training that is approximately ninety minutes long. The curriculum for the Marketplace training for returning agents and brokers consists of a self-paced review of Marketplace resources and updates. As part of the Agent Broker General Agreement, you must attest to completing the required reading and review of the materials in order for your training to be considered complete.

As always, if you have any questions, please reach out to your Cornerstone representative.

IMPORTANT UPDATE: The Humana Dependent Audit Has Been Paused

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On August 9, 2021, we announced through the Monday Minute that Humana will be conducting eligibility verifications of spouse, common law spouse, or domestic partners in its commercial population. Groups were sent notices about this eligibility verification on July 22, 2021. Groups were asked to validate dependent information with 45 days following an inquiry from Humana.

There has recently been an update from Humana.

The dependent eligibility verification has been paused to thoroughly evaluate the program and make improvements before moving forward with the verification. Humana notified employers via email on August 17, 2021 that their impacted employees do not need to take action until further notice. We’ll be sure to share related communications with you, as they are developed.

Please reach out to your Cornerstone representative with any questions.

Rev Up for Fourth Quarter with Cornerstone! Here’s What You Need to Know

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Renewal season is nearly upon us. With it comes the inevitable time crunch convergence of renewals and open enrollment. Here are a few planning tips for your group business.

Renewals

Most renewals are released after the Department of Insurance approves 2022 rating for all product types. This is usually anytime between September and November. Most are released in October. Here’s the schedule we have so far (updates will come as we get them):

CARRIER

Product

Expected Timeline

Aetna

AFA

Tentative – 60 days prior

Anthem

Grandmothered/Transitional

Tentative – mid-to-end of September

ACA

Tentative – mid-October

SOCA MEWA

Tentative – early-to-mid October

OFB MEWA

Tentative – October

Humana

All

TBD – usually 60 days out

MMO

Grandmothered/Grandfathered

Targeting 1st week in September

ACA

TBD

COSE MEWA

Targeting 1st week in September

UHC

AllSavers

60 days prior to renewal

Transition / ACA

75-90 days prior to renewal

Ohio Chamber MEWA

60-75 days prior to renewal

If your client has an ACA plan and no major health issues, you can get base rates with a member-level census. Hopefully, the numbers are encouraging enough for the group to go ahead and do FormFire. More on this later.

Beat the rush! Remember, your client doesn’t have to wait for their renewal to get applications done in FormFire. Start your January clients updating FormFire in September or stagger a few each week from September to October. We have confirmed that all major carriers are accepting applications up to 120 days old for January 1 effective dates.

But we get it, clients want to see how the renewal looks before doing FormFire. This delay starts a chain reaction that we see over and over.

Here is a GIF summary of this process:

via GIPHY

Review the Following Steps to See How Delaying FormFire Creates a Tsunami of Avoidable Issues:

  • After waiting for the renewal and reviewing, the group decides they want medically underwritten quotes. They start FormFire in late October.
  • It takes two weeks to get all the employees in FormFire after herding all the stragglers. Plus, the system is a little slower at this time because everyone is doing it at the same time.
  • Some brokers submit their quote requests just before Thanksgiving, usually Monday or Tuesday before leaving town.
  • Nobody seems to understand why it takes 5 to 7 business days to get quotes back even though everyone is doing the exact same thing at the exact same time.
  • A small handful of brokers call on Monday after Thanksgiving weekend requesting status updates for their cases submitted the prior week. Let us give the answer now to save a phone call later­­––no, we don’t have the quote back yet.
  • Quote comes back in the first week of December, broker reviews numbers and requests rate relief which takes anywhere from 2 to 5 days, depending on the carrier.
  • Final rates are negotiated about the second week of December and can be presented to the client.
  • Some clients get frustrated by the amount of time that it takes and that they only have a few days left to decide when they’re either stuck with a tough renewal or must change carriers around the holidays. Inexplicably, if you can find a solution with savings, those same clients don’t seem to get upset at all.
  • Oops! People changed their election during employee meetings­­­­––usually one of the stragglers. For underwritten quotes, that means another couple of nail-biting days waiting for the underwriter to confirm if the rates will stay the same or change? Will the group change carriers?
  • It’s January 2. Employees call in wondering where their ID card is so they can fill prescriptions or make a dental appointment. They wonder aloud to their employer if they even have insurance. The employer calls the broker to make sure because now they are wondering too.

Every. Single. Year.

Consider These Passive-Aggressive Approaches to Motivate Customers to Change

  • When they say, “I want to wait until the renewal comes out.” What you want to say is, “Great. Let’s plan our meeting to review results in mid-December. It’s only going to take you a day or two to make decisions on plan design, figure out what to charge employees, and schedule employee meetings, right?”
    Or you could say, “If we wait that long to do FormFire, that puts our timeline for getting quotes into December. Are you sure you want to wait that long?”
  • When they say, “It’s only going to take us a couple of days to complete FormFire.” You shake your head and smile, saying, “You’re such a glass-is-half-full kind of person. I like that about you.”
    Or you could say, “Could your company offer a drawing for a $25 gift card to encourage employees to complete FormFire by the deadline? We also don’t recommend giving more than five total days including a weekend because people tend to forget if you give them too much time.”
  • Try this proactive approach: “I’m . . . [insert a line from below] . . . in late December so I want to get ahead of your renewal this year. Can we track back the timeline for getting your renewal completed before Thanksgiving?”

. . . having some medical procedures . . .

. . . going back to rehab . . .

. . . going to enjoy the holidays with my family . . .

. . . running away with the circus . . .

. . . working on planning our time better so we don’t both stress out . . .

Maybe don’t use any of these tips, we’re just trying to have some fun with this. But please DO think about how you can strategize now with customers to meet their needs better, faster, and with the best possible health insurance options available.

Bona Fide, Practical, Time-Tested Tips for Planning Your Renewals and Fourth Quarter Quoting

As soon as a carrier releases ACA rates, you can get those numbers with just a member-level census. Similarly, as soon as a carrier releases their base rates for underwritten products, you can get those numbers with just a census. Unfortunately, most ACA rates will not be released until the end of September, early October.

Why bother with base rates at all? Because you can quickly rule out underwritten products if, after reviewing the rates, you see that your current/renewal rates are either in-line with or below the base rates, OR, it can demonstrate for your client what they might be leaving on the table by not shopping with their medical information.

Remember, base rates are “best-case scenario” if a group is perfectly healthy. If you compare base rates to your underwritten renewal and there’s not much difference, you and the client can decide if completing FormFire makes sense. But brokers, please know that carriers want the chance at your healthy groups! If you want to help your groups, shopping healthy cases gives the market a good idea of where their rates need to be to win new business.

All major carriers in Ohio normally accept applications dated 120 days from the January effective date. Cornerstone confirms this each year. This means that FormFire applications can be started on September 1 or after. Please make sure the Client Detail page in FormFire is set to collect medical Information or you will have an embarrassing call later.

Consider building employee meeting materials and client spreadsheets for the upcoming year right now. The new EB3 benefit booklet builder tool can help you build out professional looking packets for employees, while also putting together annual notices, SPDs, the client POP document, and exploring alternative contribution strategies to review with customers. Learn more at www.crnstone.com/eb3.

We want you to remember that your Cornerstone representative is here and happy to help you wherever you are in the planning cycle of renewing and selling business. Updates about the timing on renewals and the release of 2022 rates will come out in our Monday Minute as soon as we are notified. Contact your Cornerstone representative with any questions.

Medical Insurance Carrier Coordination with Prescription Drug Discount Programs

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The high cost of prescription drugs is a serious problem for consumers. Health insurers either own or contract with pharmacy benefit managers (PBMs) to administer covered prescription drugs in their benefit plans. In addition to processing drug claims, PBMs also negotiate with both the drug manufacturers and the retail pharmacies to determine the cost of a particular drug to the plan sponsor and ultimately the consumer.

The pricing methodologies adopted by PBMs remain complex and opaque. Components include administration and clinical fees, retail markup, MAC lists, manufacturers rebates, and more. The end result is that the final cost of a drug can and does vary wildly; the same drug is never priced the same between insurance carriers. The adoption of high deductible health plans has brought this issue to the forefront. It is quite common for a member to see the cost for a drug change dramatically when their employer changes insurance carriers.

Enter prescription drug discount programs, which have become very popular with the advent of high deductible benefit plans. Programs offered by GoodRx, Clever RX, WellRx, and many others are routinely used by consumers to shop prescription drug prices. Their easy-to-use applications put the price of any prescription drug front and center for comparison purposes. Consumers often use these tools to compare what their own insurance plan is charging for a given drug.

Now that I have discovered that the cost of my drug is less with the discount card than it is with my insurance company, what are my options? If I use the discount card, will my insurance company credit my out-of-pocket expense towards my deductible? How does that work? Cornerstone surveyed our carrier partners to find out.

Cornerstone carrier partners Anthem, Aetna, Medical Mutual, Humana, and UnitedHealthcare will all allow members to use discount drug programs and file a paper claim to get deductible credit.

The amount that the member pays out-of-pocket can be applied if the prescription is a covered benefit and the dispensing pharmacy is in network. A paper claim must be submitted to the insurance company.

The drug in question must be covered on the members prescription drug list and all applicable clinical programs or plan provisions must be satisfied (PA, step therapy, and quality limits). Only the amount the member pays out-of-pocket will be applied to the deductible/out-of-pocket.

Prescription drugs can be expensive, but your clients have options. Cornerstone’s broker advisors are available to help you determine how best to serve your clients who are faced with the high costs of medications. Contact your representative today for more information.

PCORI Fees Due to IRS No Later Than July 31, 2021

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Fees to fund the Patient-Centered Outcomes Research Institute (PCORI) are due to the IRS no later than July 31, 2021, from employers who sponsor certain self-insured health plans such as Level Funded and Health Reimbursement Arrangements (HRAs) that are not treated as excepted benefits.

How to Pay PCORI Fees
Employers that sponsor certain self-insured health plans (Level Funded) must report and pay the required PCORI fees via IRS Form 720 along with HRA plans, Quarterly Federal Excise Tax Return. Complete Part II, line 133. Employers should note “2nd Quarter” on the 720 form.

The fee applies to each Plan year that ends after October 1, 2012, and before October 1, 2021. “Plan year” refers to the plan year for your Level Funded Medical Plans or an HRA plan. Generally the plan year and the coverage period are the same. As an example, if your HRA benefit resets each January 1, your HRA plan year and your coverage period are generally a calendar year and end December 31.

Plan Year Ending Date

Fee
October 1, 2019 – September 30, 2020 $2.54
October 1, 2020 – September 30, 2021 $2.66

There are three available methods that can be used to determine the average number of lives covered under a plan for the policy year. For an HRA plan it is acceptable to use the number of subscribers only. The most commonly used method for determining the fee for your Level Funded plan is the “Snapshot Method”.

  1. Actual Count Method: A plan sponsor may determine the average number of lives covered under a plan for a plan year by adding the totals of lives covered for each day of the play year and dividing that total by the total number of days in the plan year.
  2. Snapshot Method: A plan sponsor may determine the average number of lives covered under an applicable self-insured health plan for a plan year based on the total number of lives covered on one date (or more dates if an equal number of dates is used in each quarter) during the first, second or third month of each quarter, and dividing that total by the number of dates on which a count was made.
  3. Form 5500 Method: An eligible plan sponsor may determine the average number of lives covered under a plan for a plan year based on the number of participants reported on the Form 5500, Annual Return/Report of Employee Benefit Plan, or the Form 5500-SF, Short Form Annual Return/Report of Small Employee Benefit Plan.

Payments should be made payable to the U.S. Treasury and sent by July 31, 2021 to the address below:

Department of the Treasury
Internal Revenue Service
Ogden, UT 84201-0009

The Form 720 and Form 720 instructions for this year’s filing are not yet available. Once released, you will be able to retrieve these documents from the Cornerstone website at https://www.crnstone.com/resource-center/

 

The Patient-Centered Outreach Research Institute Filing Due Dates and Applicable Rates Flier has been attached to accompany this notice.

Tools to Assist you by Carrier:

All Savers

All Savers posts the employer group’s membership information to the employer website. The employer group is required to complete and file the IRS Form 720. For general questions please contact All Savers Broker Services at 1-866-405-7174.

Humana Level Funded

Humana provides a snapshot report that shows the monthly membership employers will need when filing the PCORI. It is an employer report (click here for instructions). As a broker, the employer may grant you access if they want you to pull it for them.

Aetna Funding Advantage

The link below takes you to the Aetna Funding Advantage PCORI Fee Estimator Tool. This tool gives you guidance on calculating the PCORI fees for this group.

https://www.crnstone.com/wp-content/uploads/2020/06/pcori_tax_estimator.xlsx

 

**Anthem OH SOCA MEWA, Anthem KY Chamber Advantage, Anthem IN Chamber Health Alliance, MMO COSE MEWA, and UHC MEWA have built the PCORI fees into the premiums, therefore, you will not need to file and pay any additional fees.

Answers to ARPA Questions in Accordance with Newly Released Guidance

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Since the American Rescue Plan Act was signed into law on March 11, 2021, the impacts on COBRA and State Continuation were not fully understood until recent guidance was released. We will review the eligibility, the model notice (which is now available), and update the timeline for notification and premium assistance as it relates to COBRA. The states and several carriers have yet to weigh in on State Continuation and how it will work in Ohio, Kentucky, and Indiana, however the notification and subsidization requirements still exist. Following the review of the ARPA legislation, you will find a detailed guide by carrier and plan type outlining who is responsible for the notification, with and without a vendor, and who ultimately files and receives the tax credit.

As previously stated in the initial review of ARPA, assistance eligible individuals (AEI) will receive 100 percent subsidy for their COBRA and State Continuation premiums under two circumstances:

  1. Employee was involuntarily terminated with a qualifying event between November 1, 2019, to present. One qualifier here is that the employee was not terminated for “cause” during this timeframe. In addition, the employee is still within their 18-month period of coverage as stipulated by COBRA guidelines. State continuation eligibility again varies by carrier, plan, and state.
  2. Employee’s hours were reduced by an amount triggering the employee’s loss of eligibility for benefits.

An AEI ceases to be eligible for the premium subsidy if he/she becomes eligible for other group health coverage through a new employer, a spouse’s plan, or with Medicare.

The new model notice for those currently on COBRA and AEI’s who are eligible is available here and here and on the DOL.gov site, which are required to be sent to all AEI’s by May 30, 2021. The notice required to be sent in the case of State Continuation is called the Alternative Model Notice and is located here. So, it is important that employers begin immediately identifying their list of eligible terminated employees to assist the carrier/vendor, if applicable, with the notification requirement or so that the employer can send the model notice in a timely fashion if applicable. Individuals have 60 days to elect COBRA from the date of receipt of the notice. Due to the timing of the model notice and the notification period, it is expected that any eligible individual currently on COBRA will continue to make payments for the months of April and May. Individuals who previously declined COBRA are eligible as long as their 18-month coverage period has not expired. As well, individuals who elected and are currently on COBRA or who elected and later dropped COBRA are eligible as long as their 18-month coverage period has not expired.

COBRA subsidies will be paid at 100 percent for the AEI from April 1, 2021, to September 30, 2021. There is also a requirement for employers (plan) and issuers (carriers) to notify those individuals who elect and are awarded the subsidy when the premium subsidization is due to expire. This notice is due between 15 to 45 days prior to the expiration of the subsidy and the AEI would then be eligible for an SEP to enroll in coverage through the marketplace.

Generally speaking, whichever entity is responsible for paying the COBRA premium subsidy for the AEI, carrier or employer, will also be the party who files and receives the tax credit. The credit is taken against the Medicare tax an employer is responsible for.

The guide below will provide available information to date by carrier and by plan. If you have any questions about the requirements or available notices, please give your broker advisor a call. We recommend that you seek specific advice on filing for the premium tax credit with your accounting professional.

ARPA Cobra Guide

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