Introduction

Introduce me, my name is Ali and I blog about everything in my mind. Just to express myself, my thought and creativity.

The Summer of Stop-Loss

While this blog took the summer off, we have been keeping a close eye on the numerous developments related to stop-loss attachment point regulation.  Now that most of these developments have slowed down, at least for now, some exclusive reporting and commentary should be useful as those in the self-insurance industry (including those involved with employee benefit captives) take a collective breath.

 Pushed and prodded by a collection of health care reform advocates, federal regulators invited interested parties to submit written comments regarding the smaller insured group health plans facilitated by stop-loss insurance with “low” attachment points.

 About 150 comment letters have been submitted to date and the talking points are largely predictable. 

For the critics of self-insurance, the usual canards are widely repeated.  This request for information (RFI) process signaled a clear focus on self-insurance unlike anything that has been seen in recent years.  But the path forward remains unclear.

 That’s because the Affordable Care Act does not provide any explicit statutory authority for regulators to promulgate new rules relating to stop-loss insurance arrangements…yet that may not preclude action that could achieve the same objective.

 The HHS, DOL and/or Treasury Department (tri-agencies) could potentially rely on their general rule-making authority under ERISA or the Public Health Services Act, to play with definitions or to engage in other revisionist rule-making mischief.   The most likely scenario is that a new definition of a self-insured group health plan is crafted based on risk retention/risk transfer arrangements – thereby allowing the feds to indirectly regulate stop-loss insurance.

 So how serious is this potential threat?   The answer is complicated.

 In a private meeting with self-insurance industry representatives over the summer, a senior DOL official downplayed the prospects that any action is imminent or even likely, explaining that they felt the RFI was necessary for the agencies to get a better understanding of how the self-insurance marketplace operates in the real world.

 But conspicuously absent from the meeting, despite previously confirming their attendance, were senior HHS officials involved with the stop-loss RFI process.  This was notable because it is believed that HHS has the most aggressive regulatory agenda when it comes to self-insurance.  The Treasury Department was represented at the meeting but that agency has remained guarded about its interest and intent. 

 Any of the three agencies could initiate a rule-making process, but it is less likely if there is not a consensus among the three.

 So with that in mind, industry lobbyists have been making the rounds to congressional oversight committees to encourage that they become engaged on this issue and request that the agencies stand down now that the RFI process has been concluded and there is no “smoking gun” which would justify new regulatory action.

The most substantive meeting took place just a few weeks ago with the senior policy advisors for the Senate Finance Committee.  Given that the committee is chaired by Democratic Senator Max Baucus, who has been supportive of self-insurance in the past, it is best positioned to intervene.

The biggest push back by committee staffers was centered on the fact that the ACA does not require that self-insured employers cover essential health benefits (EHBs).   They argued that because of this “loophole” there is incentive for smaller employers to self-insurer, facilitated by stop-loss insurance with low attachment points, in order to be able to offer skimpy health care coverage as a way to save money.

Industry experts at the meeting, including executives from two leading TPAs, explained why this fear is unfounded for practical reasons.  It was then pointed out that while self-insured employers are not required to cover EHBs, they will be subject to “minimum value” requirements, which essentially accomplish the same public policy objective.

 But a final argument seemed to box in the Senate staffers.  Even if you concede the EHB “loophole” (which this blog does not), the fact is that the law was drafted in a very deliberate way to distinguish self-insured group health plans from health insurance carriers.  In this regard, any proposed changes should come back to Congress in the form of legislation as opposed to letting unelected regulators arbitrate substantive policy issues.

 The discussion was concluded with a formal request that Chairman Baucus consider exercising the committee’s oversight authority and communicate to the Treasury Department accordingly.   We understand that the request is still under consideration, so be sure to check back with this blog for updates.

Of course, the focus on self-insured plans with stop-loss insurance extends beyond Washington, DC. 

Many of our friends at the National Association of Insurance Commissioners (NAIC), have been led by the nose over the past year by health care reform advocates to take action on making it more difficult for smaller employers to self-insurer through tighter stop-loss attachment point regulation.

 At the NAIC summer meeting held a few weeks ago in Atlanta, the ERISA (B) Working Group considered a proposal to endorse “guideline amendments” to the current stop-loss insurance model act related to attachment point requirements. 

 Clearly aware of the blowback that would be directed at the NAIC if it took aggressive action that was seen to be disruptive to the health care marketplace, Working Group Chair Christina Goe of Montana tried to diffuse concerns by explaining the proposal is only advisory in nature and that the NAIC does not intend to formally amend the model act for a variety of procedural reasons.  And for good measure, committee members made it clear that they did not overstep their charge and attempt to redefine stop-loss insurance as health insurance.

 Well, it is certainly nice to hear this self-awareness of the limitations to their “charge,” but multiple federal court rulings have already confirmed that stop-loss insurance cannot be defined as health insurance, so no real favor here.

 And as far as considering a guideline amendment versus an amended model act, it’s a distinction without a meaningful difference.

 Of the 26 states that currently regulate stop-loss attachment points, only a few have adopted the model act without variation.  So it is unlikely that an amended model act would take root across the country any time soon.   No matter, as a simple NAIC recommendation on how states should regulate stop-loss attachment points could accomplish the same objective (restricting the ability of smaller employers to self-insure) much quicker.

That is because individual insurance commissioners who are already inclined to push stop-loss legislation in their states will use the NAIC recommendation as justification for action.  Given the technical nature of this issue, it’s easy to understand how this would be enough to persuade most state legislators to go along without asking too many questions.

 The NAIC working group deferred action on the proposal until its winter meeting, which in hindsight was predictable because insurance commissioners, like all political creatures, normally put off major policy decisions when Election Day looms.  Let the dust settle after November 6 and get ready for more action.

This brings us to California.

 As this blog has previously reported, the state’s insurance commissioner, Dave Jones, is a political creature who is interested in beefing up his credentials within the Democratic Party.  So it should not be surprising that he has come out as a major proponent of health care reform, and more specifically the establishment of California’s health insurance exchange, which is expected to come online in 2014.

 Self-insurance therefore became a target for political reasons every bit as much as for misinformed policy reasons in order for Commissioner Jones and his allies in the Legislature to claim credit for protecting the viability of the state’s health insurance marketplace as the exchange begins to be implemented.   A nice populist message for sure.

 One health care broker in California perhaps summed it up best when he referred to SB 1431 as the “California Health Insurance Exchange Protection Act of 2012.”

 Now that it has been confirmed that SB 1431 has been shelved, at least until a special session this December, we can look at the past as prologue.

The same stale arguments are certain to be dredged back up when some version of SB 1431 is brought back for consideration after the November elections, and the political posturing will be predictably crass.

 Equally unfortunate is that many stakeholders who will oppose SB 1431 “2.0” will likely concede the central principle once again of whether stop-loss attachment points should be regulated at all and immediately begin negotiating the numbers and formula.   Yes, political realities often dictate short term lobbying strategies based on compromise, but the longer view should not be ignored in this case.

It’s been a long hot summer for stop-loss insurance indeed, which has ended without much certainty for the future of the self-insurance marketplace.    We will see whether the coming autumn chill cools off the debate or if partisan health care reform advocates continue to overplay their hand.

Tips to Choosing Health Insurance Options

Health Insurance Options

Health Insurance is perhaps one of the many vital requirements in life today especially when you are living in a place where none is provided for you by your government. To be with the right health insurance is to be with a more secure life regardless of your age, gender or stature in life but it actually becomes a more perceive need if you are already a senior or with some particular medical condition. Choosing health insurance options may not be as easy as buying candy from a store, so to speak. Today, you will find several private insurers and they could present to you a variety of options which may not always be the right one for you. How you go about choosing, here are some tips.

Will It Cover Everything You Need?

Why would you buy a health insurance in the first place, if not for you to get covered for everything you “need”, right? Of the many health insurance options available in the market today it should be easier for you to find the one that covers for everything you need. You may want to consider looking into offers from smaller insurance companies who are most likely able to customize the health insurance according to your demands. In order to make sure that you have everything that is necessary covered, start with the most basic needs in illnesses, injuries, or any other medical services. Then level up as you go along. It should be nice if the insurer could sit down with you in discussing the plan you wish to avail of.

Would The Cost Be Just Right And Not Bring You To “Bankruptcy”?

Since you will be paying good money for the health insurance you would buy, you might as well make sure that it will be worth it. For the price to be just right, you should be able to establish the “worth” of the plan in accordance with the “inclusive”. Health insurance options can be tough on the pocket but if you will be covered for most anything you need and the payment scheme can be easy to meet, then there is no reason for you to consider it as an impractical choice. Try to work out a plan that would not get your pocket empty and be without any cash for other emergency expenses.

Is The Plan The Best Amongst The Ones You Have Reviewed?

Again, one should not forget that there is a plethora of health insurance options out there today and with the competition getting bigger, you are most likely to find competitive plans. For easier access on plans, you may want to consider using the web to search for as many of these options as you can and then make the selection after much consideration.

These health insurance options should work for you and not against you therefore you need to choose the right one for you. There is no telling when it should benefit you but surely it will anytime soon. Do not allow yourself to live without health insurance as this is a need these days.

Health Insurance Options

Health Insurance Options

The health of a person is very important and taking care of this health is primary in the considerations of that person. For this reason he will take an insurance coverage for his protection and in cases where he will get sick, he will have an insurance coverage to take care of medical expenses. People need health insurance protection and they just need to identify the health insurance options they can get so that when the time comes that this protection is needed, they will know which medical expenses will be covered by the health insurance policy.

Job-Based Health Insurance Coverage

Persons presently employed have health insurance options because they can get health insurance coverage through their work. Employers usually provide insurance coverage to their permanent employees, and provided you are not a casual worker or only work as job order workers, you can have this coverage. However, there are also employers who provide extra insurance coverage to workers who want coverage to special kinds of diseases, and employees will just pay the extra premium payments. Employers can negotiate with health insurance providers, such that premiums charged will not be too stiff. This added special health benefits will be to the advantages of their employees.

Health Insurance Options that are Non-Worked Related

If a person cannot get insurance coverage through his work, there are still health insurance options he can have like buying the insurance policy himself, if he can afford it. There are insurance policies that cover only the basic health needs and these are not so expensive. If you have no pre-existing health condition, or have never been sick of any kind for the last couple of years, you will have no problems getting this kind of health insurance coverage. There may be also insurance coverage given by your government, especially for those in the lower income groups.

Other Types of Health Insurance Coverage

There are also other kinds of insurance coverage that you can avail of. There is the comprehensive insurance that can give you coverage even for other or special types of diseases. There is also an insurance coverage that will include your whole family or give you coverage even when you are having a trip out of the country. There are several health insurance options you can avail of, especially if you can afford paying the insurance premiums. An insurance coverage that includes payments of doctor’s fees and laboratory fees may even be availed of, provided that you pay additional premium payments.

If you have just lost your job which provides you with the worked based insurance coverage, there are still options to retain your health coverage. There are insurance companies that have provisions where you can continue your health coverage, or the government may have programs for people encountering this nature of concern. There are the so called “conversion” programs of some health insurance companies where they can let people enjoy their insurance coverage even if they have just lost their jobs. There are health insurance options that people can avail of especially if they have a budget for this.

Great Savings through Personal Health Insurance

Personal Health Insurance

Health insurance these days come largely popular in that it is becoming more and more of a “must” for people no matter the status or the genre. Let us not forget that not every place in the world gets to have a government who offers nationalized health care or health insurance for its citizenry thus causing many to be without any unless they secure a personal health insurance for their individual selves. For some people this is actually a good thing because there are in fact great savings in securing your individual health insurance.

How it Works

Health insurance that is acquired by an individual from a private insurer or provider is what you can consider your personal health insurance. Today’s trend is that people no longer rely on healthcare that the government’s initiative may have been providing should they be found with the inability to pay or secure one. Many people understand that health insurance is as vital to have that they seek out great offers from one private provider to another. Insurers understand this too and look at the trend as a means to offer consumers the most competitive prices ever possible.

The Significance of Online Options

Perhaps one of the best options comes to those who seek personal health insurance by means of browsing through the World Wide Web. Online search would result to several companies offering different packages for health insurance and majority of these offers are sure to come cheaper. But to find the cheapest, you will have to request quotes from as many provider as possible and then make comparisons. What makes this means to get your health insurance quotes better is that you will not need to stretch a muscle more than you do when tapping and clicking on your computer. In as easy as this, you will be able to get the most affordable quote and it saves you costs on travel as well.

Its Effect on Employer Based Health Insurance

For many of the working class people, to seek out their own health insurance is not so much as an inconvenience but rather a good way to get better coverage while saving on money as well. Because employers at most times offer health insurance as part of the employment incentive and employers get these insurances in bulk, the cost is without a doubt at its lowest. Better personal health insurance coverage may be secured by finding separate insurance coverage that could extend your existing employment-based health insurance. This is truly the best way for any working individual to go when it comes to the acquisition of health insurance.

There ought to be good credit given to the fact that health insurance is most efficient in covering for the much needed health care for everyone in this world. Personal health insurance, being a “must have” these days pave the way for income generation on the part of private insurers but at the same time, also offers effective savings which is a great advantage for consumers.

Finding Choices to Avail Health Insurance Maternity

Healthcare for Pregnant Women

When it comes to the issue of health insurance in America, most people may indeed find it a tough concern to address because even the statistics would reveal that millions still come either without health insurance or under-insured. The same is true with health insurance maternity. Check the statistics and it will tell you that a great percentage of pregnant women in America come with inadequate prenatal care because of the lack of health insurance. So what does this leave the citizens or the pregnant women in particular to? Are there options to avail of and how does one go about it? Let us find out by reading on.

The choices for solutions to health insurance maternity are not at all missing, although not at all abundant at the same time. There may be some limit to how this type of health insurance or health care can be availed but for as long as you know your options you can definitely have a chance at avoiding really high pregnancy costs. Here are some choices in which you can turn to for maternity health care and insurance:

• Government Funded Programs – The American Federal Government is never without any initiative to help alleviate the plight of pregnant women where they have funded and run Medicaid and WIC. By checking locally you may be able to find out whether you become qualified for these federally-funded programs as in some cases, those who are already pregnant can be qualified. Women with low income can seek refuge in either the Medicaid or the WIC for health insurance maternity while keeping their fingers crossed that it qualifies them a huge amount of savings on probable bills from prenatal care to delivery.

• Membership to American Pregnancy Association – This option is good for pregnant women who are not as aware about who they can turn to for support. Joining the American Pregnancy Association may not ultimately get pregnant women the health insurance they need for their pregnancy but it will give them opportunities to find discounted health products and services. This is also a great way for pregnant women to be able to reach a doctor or nurse for possible discussions on their personal medical concerns no matter the time of day.

• Discount Programs for Maternity Health Care – It could be helpful for you to seek out possible discount programs you can avail through several private insurers first before jumping on a deal. Health insurance maternity should not be expensive which is why many private insurers come with competitive offers including provisions for discounts. This will be a good way to cut on the total and real bill for both pre-natal care and child birth.

Being pregnant and with low income should not keep you from availing of health insurance maternity that is able to address your much needed care. By finding out what your options can be, you are armed with better chances at landing a good deal and the best possible pregnancy health care.

Is Cheap Life Insurance Essential?

Life is very precious, however with so many uncertainties; we cannot predict how long we are going to remain alive. Life insurance  is very important as it gives as a form of assurance in case of uncertainty. However, life insurance can be expensive for some, who prefer to remain un-insured because of the high costs. Hope is not lost, because there is cheap life insurance, which is affordable for many families. It is important to create a source of liquidity for your family once you are gone, as well as having a source of retirement income, fund your kids’ school fees and sustain family wealth.

For some, life insurance is an impossible mission; however every individual should be capable of funding important goals. However, the economic downturn has led to people to cut down costs, therefore these hard times should not discourage you from shopping for life insurance. There is a need to consider cheap insurance, which will enable you pay in manageable premiums. Many insurance providers provide discounts to insurance buyers, which enables them to save money. The online purchase of life insurance is a cheap way to land on cheap life insurance, this is because the web technology assists the insurance companies to cut down costs, and as a result, they provide affordable insurance.

While online, you can get a variety of insurance companies offering cheap life insurance. Getting a cheap life insurance at a younger age is advantageous; this is because as you get older, you are prone to many diseases, which can limit life insurance cover. When insurance companies offer cheap life insurance, they assist you in adapting with your current financial situation. Acquiring cheap life insurance is essential and beneficial as well; this is because it can replace your salary especially if you are the sole breadwinner, in case you die.