Time & Attendance
By Charlotte Huff
Jul. 1, 2010
Before health care reform, benefits consultants worried that the insurance overhaul would sideline consumer-directed plans or perhaps jettison them altogether. Their latest sentiment: modest to substantial optimism.
As with any post-reform plan, large employers should carefully structure their consumer-directed options, typically a high-deductible policy paired with another account, such as a health savings account. Ideally, coverage would adhere to a middle ground, meeting the reform legislation’s minimum coverage requirements without becoming sufficiently generous to trigger the so-called “Cadillac,” or excise, tax, beginning in 2018.
But the myriad ways in which these high-deductible plans can be structured likely leave them well situated in the post-reform world, benefits consultants say. Along with the plans’ flexible design, they also cite other reform-related changes as being influential, such as the new limitations on another type of account, the flexible spending account.
“Frankly, these consumer-directed plans are pretty well-positioned,” says Michael Thompson, a principal in the health and welfare practice at PricewaterhouseCoopers. “I think what we’ll find is not a slowing of the process, but actually an acceleration of the process to consumer-directed and high-deductible plans in general.”
Before President Barack Obama signed health reform into law in March, consumer-directed plans were already gaining some traction among large employers, according to an annual survey conducted by the National Business Group on Health and Towers Watson. By 2011, 61 percent of employers intend to offer a consumer-directed plan; the option was provided by only 33 percent in 2006. Meanwhile, nearly half (46 percent) of those who offered a consumer-directed plan in 2010 reported enrollment of at least 20 percent.
As more employees signed up, the cost per employee declined, according to the same survey, which involved 507 employers each with at least 1,000 employees. Annual health costs per employee totaled $6,848 when at least half of the employer’s workforce enrolled in a consumer-directed plan, compared with $7,743 per employee when enrollment fell below 20 percent.
Employers are paying closer attention than ever before to those types of bottom-line statistics, says Alexander Domaszewicz, national health consumerism lead for Mercer. “None of the cost issues and very few of the quality and delivery issues have been meaningfully addressed in the reform legislation,” he says.
As employers look ahead, one worry is the excise tax. Effective in 2018, a 40 percent tax will be applied to any of a health plan’s total value that exceeds the premium threshold—$10,200 for individual coverage or $27,500 for family coverage.
But Jay Savan, a senior consultant at Towers Watson, says other economic constraints just a few years off will be more influential than the excise tax in encouraging employers to consider a high-deductible plan.
Beginning in 2014, once the health insurance exchanges are established, employers will have an incentive to keep employees’ premium contributions below 9.5 percent of their adjusted gross income if workers earn less than 400 percent of the federal poverty level, Savan says. Otherwise, the employer will have to pay a penalty—typically $3,000 annually per such employee who receives coverage through a health exchange—for surpassing that premium ceiling.
That’s a relatively low bar, Savan says. For a family of four, 400 percent of the federal poverty level is $88,200 annually. If that penalty were in effect today, that employee couldn’t pay more than nearly $8,400 annually toward health coverage.
“The plans that are most likely to allow the employer to stay under that [premium] threshold are going to be high-deductible health plans,” Savan says. “Whether they are HSA-compatible or not, it’s going to be those plans, by virtue of simple mathematics.”
The average annually family health premium, as of 2009, reached nearly $13,400, according to an annual survey by the Kaiser Family Foundation and the Health Research & Educational Trust. But the employee’s contribution averaged just $3,515.
For companies with lower-income employees, though, a relatively low premium can still exceed 9.5 percent of adjusted gross income, Savan says. Add in rising health costs and that likelihood increases, he says.
In a sense, the new health reform law contains inherent guardrails that employers should pay attention to, Domaszewicz says. On the lower end, they should make sure that coverage isn’t classified as inadequate—defined as covering less than 60 percent of allowable costs. But as their plans’ total value increases, employers also need to stay sharp, he says.
“They can’t design them [the plans] too rich because they will eventually hit this excise tax,” he says. “They can’t design them too poor or too skinny because they are not going to meet this 60 percent requirement in terms of actuarial value.”
The reform law’s move to cap FSA contributions at $2,500 annually, beginning in 2013, also may spur employees themselves to take a second look at health spending accounts, says Chantel Sheaks, a principal in Buck Consultants’ National Technical Resources Group. A parent who is facing a large bill for braces, for example, may decide to bypass the FSA and instead contribute a higher amount to an HSA-linked insurance plan, she says.
Another reform-related wrinkle, Thompson adds, is that contributions to savings accounts, including an FSA or HSA, will be counted toward the plan’s total value in determining whether it qualifies for the excise tax. “It’s only a matter of time before FSAs become less common with employers,” he says.
In the years ahead, employers may adopt other measures, such as limiting company or employee contributions to HSAs, to prevent hitting the excise tax threshold, Savan says. But the Towers Watson consultant, a longtime proponent of consumer-directed plans, remains bullish that their time has finally arrived.
By 2013, nearly all large employers will be offering the insurance option, Savan predicts. And more employees will buy in, doubling the current median enrollment of 15 percent to 30 percent or more, he says.
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