New Waiver Requirements for Mini-Med Plan Sponsors

Sponsors of “mini-med” plans that receive waivers from federal regulators to allow them to temporarily continue to offer the arrangements face new reporting requirements.

The waivers are needed because most, if not all, mini-med plans run afoul of federal rules—mandated by the health care reform law—that set a minimum annual dollar limit on essential benefits that health care plans must provide. The minimum limit, under regulations released earlier this year, is $750,000 in 2011, $1.25 million in 2012 and $2 million in 2013.

Starting in 2014, the law bars annual limits for essential benefits.

The minimum limits allowed for the next three years, though, are far more than the maximum benefits provided through mini-med plans, which typically are offered to low-wage, part-time or seasonal employees who, in many cases, could not afford coverage in other group plans offered to full-time employees.

Until 2014, mini-med plan providers can obtain waivers from the required minimum annual benefit in situations where meeting those requirements would result in a significant decrease in access to benefits or significantly increase premiums, the Department of Health and Human Services said in guidance issued in September. Several dozen organizations have received the waivers.

In a supplemental guidance issued late last week, HHS regulators said as a condition of receiving waivers, mini-med sponsors will have to provide written notification to enrollees that the plan does not meet the annual limit requirements and that a waiver has been approved.

The notice also will have to give the dollar amount of the annual limit requirements and state that the waiver will be for only one year. HHS said it intends to soon provide a model waiver notice that sponsors could provide to enrollees.  

Filed by Jerry Geisel of Business Insurance, a sister publication of Workforce Management. To comment, e-mail editors@workforce.com.

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