Posts Tagged: mini-med

Annual Limit Waiver Applications – Update

in Affordable Care Act

I recently talked to HHS regarding an annual limit waiver (i.e., mini-med waiver) that i filed on behalf of a client.  HHS requested additional information, which is not new.  But, what is new, is that one of the additional pieces of requested information is a hypothetical calculation of premiums for the next year, assuming that the plan sponsor had to raise the annual limit to $750,000.  Theoretically, this sounds like good information for HHS to request.  But, this information takes time to produce and is not included in any of the HHS guidance regarding the waiver application process.  Anyone filing a new waiver… Continue Reading

Annual Limit Waiver Guidance Updated

in Affordable Care Act

In previous posts I discussed the annual limit waiver process for mini-med plans as well as the upcoming MLR rules regarding mini-med plans.  Today, OCIIO amended the annual limit waiver application process for mini-med plans, including adding a participant notice requirement.  This notice is yet to be posted to the website, but it is required to be sent to participants in a plan that has obtained an annual limit waiver.  OCIIO also announced its intention to provide a special methodology for mini-med plans to better satisfy the upcoming MLR rules.   The special methodology is expected to be available for at least the first year the MLR rules are… Continue Reading

NAIC Finalizes MLR Rules

in Affordable Care Act

Today, the NAIC finalized its controversial MLR regulations, and have sent them to HHS.  In turn, HHS will turn the MLR rules into regulations under the Affordable Care Act.  In the process, HHS can certainly revise or tweak the MLR rules, including, for example, to make it easier for mini-med plans to pass the requirements.  A few weeks ago we posted a news release by HHS stating that they understood the challenges that mini-med plans face and they intended to revise the MLR rules as appropriate for mini-meds.  The link below discusses the passage of the final rules. http://www.naic.org/Releases/2010_docs/naic_adopts_final_mlr_regs.htm

Mini-Med Plans – Round 2

in Affordable Care Act

As I previously discussed, HHS has indicated a willingness to make an exception in the upcoming MLR regulations for mini-med plans.  However, currently, it is unclear how and to what extent that exception will apply.  Unfortunately, employers need to make decisions now for annual enrollment materials.  Because no one knows what the MLR exception will look like, one solution to this issue is to simply self-insure your mini-med option.  A self-insured mini-med option is not subject to the MLR regulations.  However, remember, you still need to file for a waiver from the annual limits even if the option is self-insured.

Relief for Mini-Med Plans from Restrictive MLR Rules

in Affordable Care Act

Yesterday, many plan sponsors of mini-med plans publicly noted that the upcoming MLR regulations may force them to terminate their mini-med plans. Currently, the NAIC has published draft rules. Next month HHS is required to take that draft and turn it into proposed regulations on the medical loss ratio standards. Moments ago the Director of OCIIO released a statement saying in part that when OCIIO releases the proposed MLR regulations, it fully intends to exercise discretion under the new law to address the special circumstances of mini-med plans in the medical loss ratio calculations. According to the Affordable Care Act,… Continue Reading