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What is Creditable Medicare Part D Coverage?

Medicare Part D notices are due before October 15,2020. But what does that mean and how do you know if your coverage is creditable?

If you have any type of group health plan the notice is sent to advise plan participants as to whether their prescription drug coverage is “creditable.”

What is Medicare D Creditable Coverage? – The Medicare Modernization Act made it a requirement that entities that offered plans which included prescription drug coverage had to disclose to all Medicare-eligible individuals whether that prescription drug coverage was “creditable.”

Defining Creditable – For the purposes of this requirement, “creditable” means that the coverage is expected to pay as much as the standard Medicare prescription drug coverage. Among the 2020 parameters for what is considered “standard” under Medicare D are:

  • Deductible: $435.00
  • Initial coverage limit: $4,020
  • Out-of-pocket threshold: $6,350

Determination of Creditable Coverage
The prescription drug plan is deemed to be creditable if it:

  • Provides coverage for brand and generic prescriptions
  • Provides reasonable access to retail providers and mail order coverage
  • Is designed to pay on average at least 60% of participants’ prescription drug expenses

The plan must also satisfy one of the following criteria:

  1. The prescription drug coverage has no annual benefit maximum benefit or a maximum annual benefit payable by the plan of at least $25,000
  2. The prescription drug coverage has an actuarial expectation that the amount payable by the plan will be at least $2,000 annually per Medicare-eligible individual
  3. For entities that have integrated health coverage, the integrated health plan has no more than a $250 deductible per year, has no annual benefit maximum, or a maximum annual benefit payable by the plan of at least $25,000 and has no less than a $1,000,000 lifetime combined benefit maximum.

Notification
The creditable or non-creditable coverage notice must be provided to Medicare Part D eligible individuals who are covered or who apply for the plan’s prescription drug coverage. This includes active, retired, disabled, and COBRA beneficiaries and dependents. The notice must be furnished no later than October 14. The Part D Annual Election Period runs from October 15 through December 7 of 2020.

It is often difficult to determine which participants are Medicare D eligible, so the prudent solution is to send the notification to ALL plan participants prior to October 14. Click here for a guide that  provides a calculator methodology for determining creditable coverage.

There is also a necessary notification requirement for entities to complete the Online Disclosure to CMS Form to report the creditable coverage status of their prescription drug plan. The disclosure should be completed annually no later than 60 days from the beginning of a plan year, within 30 days after the termination of a prescription drug plan, or within 30 days after any change in creditable coverage status.

Penalties
While there are no formal penalties attached to non-conformance of the requirement, the Medicare-eligible individual may incur a late enrollment penalty if notification as to non-creditable coverage exists and that individual then attempts to enroll in a Medicare Part D plan.

 

Employee Benefit Advisors provides employee benefits, tax-advantaged healthcare, compliance guidance for ACA and Health & Welfare DOL Audits, and PEO Advisory & Consulting Services.

Let the dogs out!

Surprise medical bill? – Surprise medical billing applies to fully-insured commercial insurance plans.   No federal laws exist to prevent surprise medical bills and of the states that do less than half provide comprehensive legislation.   Employees are confused when they receive a surprise medical bill and it generally reflects poorly on the company plan when it occurs.

Bill Dog was made for the moment a confusing medical bill arrives. Members can be confident before paying any medical bill. Bill Dog researches and explains every situation to our members.

  • What is the bill for?
  • What are the codes?
  • Are the charges too high?
  • I have insurance, why do I have this bill?
  • I am confused.

Bill Dog works directly with members, providers, and insurance companies to resolve issues, support appeals, and assist with price negotiations. Bill Dog provides an easy way to verify any medical bill so it can be negotiated and paid with confidence. It is easy to use. You can reach them by phone, chat, email or direct message. Codes and charges are verified. Billing errors are identified and corrected. Appeals and price negotiations are supported. It is results driven. Errors are identified and corrected — claims denials and out of network charges are verified.

 

Employee Benefit Advisors provides employee benefits, tax-advantaged healthcare, compliance guidance for ACA and Health & Welfare DOL Audits, and PEO Advisory & Consulting Services.

COVID-19 Disability Claims

Several clients have asked questions related to COVID-19 and their group disability insurance. Here’s a compilation of how carriers are administering claims.

Question: Is someone automatically disabled if he/she is placed under a quarantine related to the Coronavirus?

Answer: No. Standard policy language requires that an insured be disabled from his/her own occupation. Therefore, an insured is not automatically considered disabled if under a quarantine for any reason. However, some policies may contain quarantine provisions. It is important that you check your policy or (if self-insured) plan document, as this will dictate how claims are administered.

Question: Will a disability claim for an insured who is under a quarantine related to the Coronavirus be approved?

Answer: Possibly. Every claim is reviewed based on the disability policy language and the unique facts of the insured’s situation, including factors such as the diagnosis and medical certification; the progress of the virus/condition; the specific quarantine that the insured is subject to; and the insured’s ability to work remotely, among others.

Claims submitted listing a diagnosis of Coronavirus will be processed in compliance with all applicable contract provisions. In general, to be eligible to receive benefits, an insured must provide proof that he/she is:

  • Under the care of a Health Care Provider who is certifying the insured’s disability; AND
  • Unable to perform his/her occupation in the workplace or at home via remote access.

If the employee is symptomatic, then he/she may have a qualifying condition under FMLA (or even the ADA) which would require him/her to take leave. An important consideration is that the employee must be quarantined and not able to return to work. To the extent the quarantine is optional and the employee is symptomatic, the employee may also qualify for FMLA.

Situations involving furloughs or layoffs may be more complex. This may include eligibility for coverage for those who were actively at work prior to a furlough or layoff on a prior carrier’s policy. How will pre-existing conditions be administered? What about employees whose hours are reduced below the minimum hours required in the policy definition for eligibility? – There are many scenarios that may need to be reviewed by a broker with in-depth knowledge of contract language and claims experience.

 

Employee Benefit Advisors provides employee benefits, tax-advantaged healthcare, compliance guidance for ACA and Health & Welfare DOL Audits, and PEO Advisory & Consulting Services.

Bringing People Back to the Workplace Safely & Efficiently

Key to bringing people back is developing and implementing industry best practice safety and wellness protocols.

Meridian’s temperature sensing Personnel Management Kiosk is designed to help protect the health and safety of both employees and guests by helping prevent anyone with a temperature or those without access from entering a facility.

Features

  • Temperature Verification
  • Facial Identification
  • Temperature Threshold Alarms
  • Pedestal & Countertop Configurations

Designed to monitor multiple kiosks in remote locations it is ideal for businesses requiring system security and remote performance management.

Temperature Management Solutions help balance the need to get back to business as quickly as possible while ensuring workplace health and safety. Easy to setup and use. Potential integration, current and development, will make this product a powerful monitoring service tool. More information available at www.meridiankiosks.com.

 

Employee Benefit Advisors provides employee benefits, tax-advantaged healthcare, compliance guidance for ACA and Health & Welfare DOL Audits, and PEO Advisory & Consulting Services.

OSHA Recommends that Employers Encourage Workers to Wear Face Coverings at Work

As businesses open and employees return to work, large numbers of employees of workers will be required to wear faces masks in the workplace.

The Occupational Safety and Health Administration (OSHA) has published a series of answers to frequently asked questions (FAQs) regarding the use of masks in the workplace to help employers provide a safer work environment. The guidance outlines the differences between cloth face coverings, surgical masks and respirators.

Guidance includes:

  • Cloth face coverings are not considered personal protective equipment and employers are not required to provide them. (Employee Benefit Advisors believes this is an extremely important as it could provide the employer a layer of liability protection.)
  • OSHA generally recommends that employers encourage workers to wear face coverings at work.
  • Cloth face coverings are not a substitute for social distancing measures.
  • OSHA suggests following CDC recommendations, and always washing or discarding cloth face coverings that are visibly soiled; and
  • Employers must not use surgical masks or cloth face coverings when respirators are needed.

Click here for more information.

 

Employee Benefit Advisors provides employee benefits, tax-advantaged healthcare, compliance guidance for ACA and Health & Welfare DOL Audits, and PEO Advisory & Consulting Services.

COVID-19 and Fat People

I posted Fat People Have Issues November 19th. 2014. – Medical Issues.

Once again, before offending anyone – I posted the politically incorrect title in hopes of getting more people to read. I like fat people, many of my friends are fat. And to be honest, I would like to lose a few lbs. So please take it in good humor. I do not need hate mail. I also recognize some people have genetic challenges.

The statistics for COVID-19 are showing 94% of the deaths have underlying medical conditions, 88% have two conditions and 19% at least one. Elevated blood pressure is the number one underlying medical condition at 53%, overweight 42%, diabetes 32%.

One of the most effective ways to ensure quality healthcare services is to not need it in the first place. All those overweight, please raise your hand. All those currently being treated for a preventable healthcare issue raise your hand. Employee Benefit Advisors has seen, time after time with my own clients, that weight loss is the number one factor to controlling health care costs.

One my biggest beefs with Obamacare is that it did nothing to promote a healthy lifestyle. A good BMI can resolve many medical issues. Maintaining a proper BMI has the potential for the doctor to remove you from your high blood pressure, cholesterol, diabetes, and other medications.

As for COVID-19, it is recommended people with underlying conditions stay home during phase 1 and 2 of the reopening of the economy.

Want more info on the Dietary Impact on Health? Check out https://ebafl.com/dietary-impact-on-health/

 

Employee Benefit Advisors provides employee benefits, tax-advantaged healthcare, compliance guidance for ACA and Health & Welfare DOL Audits, and PEO Advisory & Consulting Services.

Florida Department of Health

The Florida Department of Health has received accolades from the Presidential Response Team during the daily briefing. Doctor Deborah Brix has mentioned several times it is an ideal resource and one that other states should try to emulate.

Florida Health 201 Novel Coronavirus Response (COVID-19) https://floridahealthcovid19.gov/. The site includes the county-specific Surveillance Dashboard I mentioned in my previously blog.

 

Employee Benefit Advisors provides employee benefits, tax-advantaged healthcare, compliance guidance for ACA and Health & Welfare DOL Audits, and PEO Advisory & Consulting Services.

Florida’s COVID-19 Data and Surveillance Dashboard

The link below provides some very insightful data regarding the spread of COVID-19.

https://experience.arcgis.com/experience/96dd742462124fa0b38ddedb9b25e429

The chart in the lower left is particularly interesting. Obviously, one would expect an increase in cases as the number of tests increase. However, note the trend of the decrease in the number of new cases.

What does this mean? To me it says we may be getting ready, hopefully, to start the economy back up. It also suggests we should start thinking about how to restart our businesses. – Need help planning the restart? I know people, experts – people that can help. – Let me know what you need, I’ll help you find the right person.

 

Employee Benefit Advisors provides employee benefits, tax-advantaged healthcare, compliance guidance for ACA and Health & Welfare DOL Audits, and PEO Advisory & Consulting Services.

Employers of Choice – Furlough vs. Layoff

The COVID-19 relief packages have passed based on three fundamentals; (1) providing economic support to both businesses and individuals (2) keeping people employed, and (3) keeping people insured. Financing payroll may not be possible, after all it’s generally the largest expense. Companies may to need decide between a Layoff and Furlough.

Layoff (noun) – temporary or permanent separation of employment
Furlough (noun) – considered an alternative to a layoff, generally a short-term temporary layoff from employment
COVID-19 has forced many workers to either be laid-off(v) or furloughed(v).

When considering Furlough vs. Layoff, there are three reasons a furlough is viewed more favorable, especially under these circumstances.

      • Flexibility – because business reality is changing day to day and sometimes hour to hour, a furlough allows an employer the ability to reduce work days and/or hours of its employees all the way down to not working at all once it gets to that point.  But for those employers that are not yet at the point of having to make a final decision on cuts across the board, a furlough is a good option.
      • Employee Centric – employees who are laid off are cut off from benefits as per plan rules (which could be from the date of notice), once they are laid off. With a furlough being considered more like a leave of absence then a termination of employment, employers are able to provide benefits at a minimum for 30 days and can even opt to continue to pay for benefits throughout the duration of the furlough. In light of how this pandemic is affecting workers finances and health, doing so certainly signals that the Employer is making decisions with the employee impact in mind and not simply considering the bottom line.
      • Ability to Regain Ground Quickly – Once the crisis ends, and businesses are able to reopen, it’s going to be critical for businesses to be able to quickly staff back up to meet demands and furloughing employees rather than laying employees off and risking them seeking other employment due to the “permanency” that layoffs signal, would allow an employer to quickly bring back experienced, already trained employees to restart operations and servicing customers.

    Special thanks to Ivelices Thomas, HR & Beyond www.hrandbeyond.com, for her input.

     

    Employee Benefit Advisors provides employee benefits, tax-advantaged healthcare, compliance guidance for ACA and Health & Welfare DOL Audits, and PEO Advisory & Consulting Services.

Small & Midsize Employers – two new refundable payroll tax credits

IR-2020-57, March 20, 2020

The U.S. Treasury Department, Internal Revenue Service (IRS), and the U.S. Department of Labor (Labor) announced that small and midsize employers can begin taking advantage of two new refundable payroll tax credits, designed to immediately and fully reimburse them, dollar-for-dollar, for the cost of providing Coronavirus-related leave to their employees. This relief to employees and small and midsize businesses is provided under the Families First Coronavirus Response Act (Act), signed by President Trump on March 18, 2020.

The Act will help the United States combat and defeat COVID-19 by giving all American businesses with fewer than 500 employees funds to provide employees with paid leave, either for the employee’s own health needs or to care for family members. The legislation will enable employers to keep their workers on their payrolls, while at the same time ensuring that workers are not forced to choose between their paychecks and the public health measures needed to combat the virus.

Key Takeaways

Paid Sick Leave for Workers

  • For COVID-19 related reasons, employees receive up to 80 hours of paid sick leave and expanded paid child care leave when employees’ children’s schools are closed or child care providers are unavailable.

Complete Coverage

Employers receive 100% reimbursement for paid leave pursuant to the Act.

  • Health insurance costs are also included in the credit.
  • Employers face no payroll tax liability.
  • Self-employed individuals receive an equivalent credit.

Fast Funds

Reimbursement will be quick and easy to obtain.

  • An immediate dollar-for-dollar tax offset against payroll taxes will be provided
  • Where a refund is owed, the IRS will send the refund as quickly as possible.

Small Business Protection

  • Employers with fewer than 50 employees are eligible for an exemption from the requirements to provide leave to care for a child whose school is closed, or child care is unavailable in cases where the viability of the business is threatened.

Easing Compliance

  • Requirements subject to 30-day non-enforcement period for good faith compliance efforts.

 

Employee Benefit Advisors provides employee benefits, tax-advantaged healthcare, compliance guidance for ACA and Health & Welfare DOL Audits, and PEO Advisory & Consulting Services.

 

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