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Enforcement Delayed for Health Plan Identifier Regulations


On October 31, 2014, the Department of Health and Human Services (HHS) announced that, until further notice, it will delay enforcement of regulations related to obtaining the Health Plan Identifier (HPID) and using the HPID in Health Insurance Portability & Accountability Act (HIPAA) transactions that were adopted in the HPID final rule.

This enforcement delay applies to all HIPAA covered entities, including health care providers, fully insured and self-funded health plans, and health care clearinghouses.

The National Committee on Vital and Health Statistics (NCVHS), an advisory body to HHS, issued a written recommendation asking HHS to review the HPID requirement. The NCVHS recommended that the HPID not be used in HIPAA transactions given that the health care industry has already adopted a "standardized national payer identifier based on the National Association of Insurance Commissioners (NAIC) identifier."

The NCVHS also outlined issues with the HPID that were raised at its hearings, including:

  • Lack of clear business need and purpose for the HPID
  • Confusion about how the HPID would be used in administrative transactions
  • Challenges faced by health plans defining controlling health plan (CHP) and subhealth plan (SHP)
  • Use of the HPID for group health plans that do not conduct HIPAA standard transactions
  • Cost to health plans, clearinghouses, and providers if software has to be modified to account for the HPID
What does this mean?

Insured plans and self-funded health plans that have not already obtained an HPID do not need to do so until further notice. Prior to HHS's announcement, the following compliance dates were in effect:
  • Health plans with annual receipts of $5 million or more were required to obtain HPIDs by November 5, 2014.
  • Small health plans, defined as plans with annual receipts of $5 million or less, were required to obtain HPIDs by November 5, 2015.
  • All plans that generate the electronic transactions were required to use the identifier in those transactions by November 7, 2016, pending the "operating rules" of the transactional use.
These compliance dates are now delayed, even though the HPID regulations have not specifically changed. At this time, it is unclear whether or not HHS will adopt the recommendations of the NCVHS on a permanent basis. In the interim, group health plan sponsors and administrators should stay tuned for further announcements from HHS.

What is the Health Plan Identifier?

The health care reform legislation requires all health plans to obtain a ten-digit "unique identifier" from a government sponsored agency, known as the Health Plan Identifier (HPID). The HPID is intended to streamline electronic transactions between carriers, administrators, health care professionals, and financial institutions.

When obtaining the HPID, health plans are divided into controlling health plans (CHPs) and subhealth plans (SHPs), two terms that were introduced in the final rule.


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Federal regulators announced plans to close a loophole in the Affordable Care Act that allows large employers to offer plans that don't cover in-patient hospital stays.


USA TODAY reported that the Centers for Medicare and Medicaid Services would do so.

To meet the ACA's "minimum value" test, health plans for individuals and those working for smaller employers must include coverage within at least 10 categories of "essential health benefits" that include maternity care, prescription drugs and hospitalization. The health care law is much more stringent about what health insurance must cover for these people than it is for those working at large employers.

Plans that cap the number of hospital visits or offer no hospital coverage were believed to pass the ACA's minimum value test if other coverage for doctors and prescription drugs was generous enough. But CMS is proposing that employers have to offer at least one plan that meets the minimum value test.

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2015 Retirement Plan Limits Announced


The IRS has announced cost-of-living adjustments affecting dollar limitations for retirement plans and related items for tax year 2015. Highlights include:

  • The contribution limit for employees who participate in 401(k), 403(b), and most 457 plans is increased from $17,500 to $18,000.
    • The catch-up contribution limit for those aged 50 and over is increased from $5,500 to $6,000.
  • The limit on annual contributions to an individual retirement arrangement (IRA) remains unchanged at $5,500.
The deduction for taxpayers making contributions to a traditional IRA is phased out for singles and heads of household who are covered by a workplace retirement plan and have modified adjusted gross incomes (AGI) between $61,000 and $71,000, up from $60,000 and $70,000 in 2014.
  • For married couples filing jointly, in which the spouse who makes the IRA contribution is covered by a workplace retirement plan, the income phase-out range is $98,000 to $118,000, up from $96,000 to $116,000.
  • For an IRA contributor who is not covered by a workplace retirement plan and is married to someone who is covered, the deduction is phased out if the couple's income is between $183,000 and $193,000, up from $181,000 and $191,000.

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Online Access to Federal SHOP Expected to Begin November 15th


Online enrollment for small employers to purchase employee health coverage through the federally-facilitated SHOP Marketplace (Small Business Health Options Program) is expected to open on November 15, 2014. Small employers may work with their current agent or broker to apply for and enroll in coverage, so long as the agent or br oker has completed the SHOP registration requirements

Using the SHOP Marketplace
To work with an agent or broker in the federally-facilitated SHOP Marketplace, an employer must create an authorization with the agent or broker within the SHOP Marketplace. The authorization will allow the agent or broker to help the employer fill out the SHOP application and manage the employer's SHOP account.

Agents and brokers can assist small employers with:

  • Determining if their businesses have 50 or fewer employees and are eligible for SHOP;
  • Applying for insurance for their employees;
  • Reviewing and comparing price, coverage, quality, and other important features of available SHOP plans;
  • Enrolling in the SHOP plan the employer chooses; and
  • Understanding eligibility for the Small Business Health Care Tax Credit.
Note that employers located in a state operating its own SHOP Marketplace must follow that state's application and enrollment process.

Reminder: Employers Must Provide Exchange Notice to All New Employees All employers covered by the Fair Labor Standards Act are required to provide new employees with a notice regarding the Health Insurance Marketplace (also called the Exchange), regardless of whether the employer offers a health plan. The notice must be distributed to each new employee within 14 days of his or her start date.

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Social Security Benefits to Increase in 2015


Monthly Social Security and Supplemental Security Income (SSI) benefits will increase 1.7 percent in 2015, the Social Security Administration has announced. The 1.7 percent cost-of-living adjustment (COLA) will begin with benefits that Social Security beneficiaries receive in January 2015, while increased payments to SSI beneficiaries will begin on December 31, 2014.

Certain other changes that take effect in January of each year are based on the increase in average wages. Based on that increase, the maximum amount of earnings subject to the Social Security tax will increase to $118,500 from $117,000.

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Ebola and the Workplace: Guidance for Employers


Ebola is a rare, but often fatal, disease caused by infection with one of the Ebola virus strains. Symptoms of Ebola may appear anywhere from 2 to 21 days after exposure to the virus and include fever, severe headache, muscle pain, weakness, and stomach pain. According to the U.S. Centers for Disease Control and Prevention (CDC), individuals can only get Ebola from touching:

  • Bloodor body fluids of a person who is sick with or has died from Ebola;
  • Contaminated objects (e.g., needles); or
  • Infected fruit bats or primates (e.g., apes and monkeys).
Individuals cannot get Ebola through the air, through water, or through food grown or legally purchased in the United States.

Protecting Workers Although Ebola does not pose a threat to most U.S. workers, exposure may be more likely in certain sectors, including the health care, airline and other travel service, and laboratory industries. Employers in these industries should be familiar with certain standards under the federal Occupational Safety and Health Act (or state-specific standards) that may be applicable in the event of possible worker exposure to the Ebola virus. Interim guidance is available for protecting workers whose work activities are conducted in an environment that is known or reasonably suspected to be contaminated with Ebola.

Employers in all industries can help prevent the spread of illness by encouraging simple hygiene practices. To help protect against Ebola, the CDC advises all individuals to follow some simple do's and don'ts:
  • DO wash your hands often with soap and water or use an alcohol-based hand sanitizer;
  • DON'T touch the blood or body fluids of those who are sick; and
  • DON'T handle items that may have come in contact with a sick person's blood or fluids (e.g., clothes, bedding, or medical equipment).

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Employers Subject to ACA Transitional Reinsurance Program Must Submit Annual Enrollment Counts by November 15th


A new form is now available for employers sponsoring certain self-insured plans ("contributing entities") to make contributions required under the Affordable Care Act's Transitional Reinsurance Program to support payments to individual market issuers that cover high-cost individuals.

Contributing Entities

Health insurance issuers and certain self-insured group health plans offering "major medical coverage" that is part of a commercial book of business are contributing entities. A contributing entity must make reinsurance contributions on behalf of its enrollees in plans that provide "major medical coverage" unless one of the exceptions provided under the law applies to such coverage.

Although a contributing entity is responsible for the reinsurance contributions, it may elect to use a third party administrator or administrative services-only contractor for submission of enrollment data and the transfer of the reinsurance contributions.

Reinsurance Contribution Process To successfully complete the reinsurance contribution process, contributing entities (or third-party administrators or administrative services-only contractors on their behalf) must register on www.pay.gov and submit their annual enrollment count of the number of covered lives of reinsurance contribution enrollees for the applicable benefit year. For the 2014 benefit year, the annual enrollment count submission deadline is November 15, 2014.

After contributing entities complete the ACA Transitional Reinsurance Program Annual Enrollment and Contributions Submission Form, their annual contribution amounts to be remitted will be auto-calculated. Contributing entities will then enter their payment information and will be given a chance to review and submit the calculated reinsurance contributions.


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Summary Plan Description


Do you have your Summary Plan Description for your benefit plan? As per ERISA you are required to have a Summary Plan Description in place, or you can be subject to fines/penalties from the Department of Labor. Please call dedicated servicing representative today to review what is required and make sure you are incompliance with the Affordable Care Act..

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New formulary drug list for Oxford Small group business


The attached Prescription Drug Lists (PDLs) are effective on January 1, 2015 for Oxford small group plan members. These PDLs also apply to any new Oxford pharmacy benefit groups, effective on January 1, 2015.

Please reference the new Prescription Drug List and share with plan participants accordingly. PDLs are posted to the oxfordhealth.com Member and Employer. Fliers are also available there, called "Updates to your prescription benefits," highlighting changes made for 2015.
  • Members taking select maintenance medications impacted by a change will receive a letter noting lower-cost alternatives prior to January 1, 2015. Members have also been directed to oxfordhealth.com to learn more about their pharmacy benefit, and have been informed that they may call us at the phone number on their health plan ID card with questions. Members should use the phone number on their health plan ID card designated "For Members" for their medical and pharmacy questions.
  • The PDLs and the Updates fliers are posted on the oxfordhealth.com Member portal under Tools & Resources > Practical Resources > Your Pharmacy Coverage > Prescription Drug List.
Oxford has also communicated updated PDL information to physicians and pharmacies.

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November 2014









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