Last post of 2014

The FEHBlog trusts that his readers have been enjoying the holiday season. Today is the end of 2014. The new benefit year for federal and postal annuitants begins tomorrow while the new benefit year for federal employees begins with the first day of the first 2015 pay period which appears to be January 12.

ACA-wise, the employer shared responsibility mandate takes effect tomorrow for the federal government and all other employers with 100 or more full time employees. OPM and the Postal Service already have handled this issue by rolling out coverage to employees who work at least 30 hours per week / 120 hours per month. Surprisingly to the FEHBlog, the Labor Department has not listed in the November 2014 unified agenda a rulemaking project for the ACA requirement that employers with 200 or more employees auto-enroll new employees in their health benefit plan.

Also missing from the unified agenda is an anxiously anticipated regulatory project that will provide guidance on the 40% excise tax on high cost health coverage (colloquially known as the Cadillac tax) that takes effect in 2018 — now only three years away. Unless of course Congress repeals it which is not out of the question,

Another major ACA provision this is missing in action is Public Health Service Act § 2717 which required the HHS Secretary to create health care quality improvement standards for group health plans and health insurance issuers within 24 months after enactment – March 23, 2012 — almost three years ago. Once implemented, group health plans and health insurance issuers would be required to annually report their compliance with these standards to plan enrollees and the government.

The new year also means that the ICD-10 coding set compliance data for health plans and health care providers is only 10 months away.  2015 also was anticipated to be the year in which health plans would be required to certify with HHS their compliance with the HIPAA operating rules but that obligation hinges on the issuance of an HHS rule. The unified agenda predicts that this rule will be issued in July 2015 which suggests to the FEHBlog that the certification requirement deadline will be pushed out into 2016. But you never know.

While on the topic of the ACA, the non-profit co-op plans created by the ACA have been in the news lately. The Des Moines Register reports that the Iowa co-op called Coopportunity Health has come under state receivership. Modern Healthcare reports that HHS recently provided $300 million in additional funding to these coops which the FEHBlog has described as the ACA’s Solyndras. The government has provided $2.5 billion in funding to these co-ops.  The spending simply was unnecessary, in the FEHBlog’s view.

Happy New Year to all!

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