Why are so many Americans deferring healthcare or going broke because of it? Wasn’t the ACA supposed to fix that problem?

The easy-simple-uncomplicated-straight forward solvable answer is that premiums have increased so much that people can’t afford premiums for anything but bronze plans. That means out of pocket cost for a single person of as much as $8,000 plus premium.

There is a solution to this and it will help all employers control costs while maintaining a healthy-loyal staff while reducing cost for both employer and employee.

Health Reimbursement Arrangements (HRAs) are a popular type of employer sponsored plan that can be used to reimburse an individual for qualified medical expenses and certain types of health insurance. HRAs are funded by the employer, and cannot be funded via employee salary reductions. Technically, HRAs are not a health plan, as we commonly think of plans, but rather they are an ACA and IRS supported method for employers to reimburse their employees for healthcare expenses. And they work!

In fact, HRAs worked so well for small employers that certain Insurers in California
threaten punitive actions against brokers to prevent brokers from showing HRAs to their clients.

The Court in a recent anti-trust lawsuit in California decided in favor of the Plaintiff and small employers when it issued an injunction preventing the Insurer from restricting access to these employer/employee friendly programs called HRAs. For years, Insurers in California threatened broker’s commissions and contracts if their clients implement HRAs. That is, until one TPA had seen enough. Now, Insurers no longer threaten brokers to restrict HRAs; but more about that in a future post.

The regulations and guidance issued under the Affordable Care Act, make it difficult for HRAs to be offered on a stand-alone basis, other than for retiree-only groups. The most common means for implementing HRAs, and the safest for employers, is to integrate the HRA with a group health plan that already complies with the standards of the ACA.

The Trump Administration issued an Executive Order that directs the DOL and the Departments of Treasury and Health and Human Services to consider proposing regulations or revising guidance to increase the usability of HRAs It also directs them consider means to expand employers’ ability to offer HRAs, and to allow HRAs to be used in conjunction with non-group coverage.

HRAs are under-utilized in today’s market so the Trump EO may be a shot of adrenaline to insurance brokers to look at HRAs as a creative way to help their clients lower cost and improve benefits.

The point is that HRAs have a 15 year track record of proven results for small employers that demonstrates how HRAs can work effectively to reduce costs. That 15 year track record also shows why it is that HRAs improve benefits every time they are implemented. The track record was accomplished in CA and we all know that CA is one of the most expensive states for healthcare premium and unit cost.  That’s a pretty good state to set an impressive track record.

The HHS may expand HRAs in a manner to give larger employers the freedom to reimburse employees for premiums on their individual plans (non-group) through an HRA. This idea of “premium reimbursement for individual plans” may prove disruptive to the group market as often happened with defined contribution plans over the past 20 years. If employers commit to provide a benefit plan then employers will benefit if they choose to maintain the integrity of the “group” plan to assure proper pricing in future years.

We’ll keep an eye on the market but in the interim, every employer with 2 employees to 2,000 employees should demand that their broker present them with an HRA option. That’s not advice, its common sense!

HRAs work for everyone, including Insurers, which once again proves that we’re all in this together.

Until next week.

Mark Reynolds, RHU
559-250-2000
mark@reynolds.wtf
It means “Walk the Faith”.

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