Column 27 Deadlines HSA

As a benefits broker/consultant I often advise my employers that our open enrollment deadlines need to be at least a week or even two prior to the insurer deadlines.  In addition we rarely give employees a long time to make a decision for open enrollment.  Why? Because in 35 years of doing this work, I find that most people will wait until a few days or the day before the deadline to actually look at the packet or review the information.  This is a combination of human nature to procrastinate and partly due to the fact that we all have very busy lives.  We tend to take care of the urgent rather than rank tasks by priority of importance.

So the current state of the ACA deadline issues is really no surprise to anyone.  Last Monday, it was difficult to get access to the Covered CA website as it was the "last day" to sign up for a 1/1 effective date.  In an effort to accommodate the late comers the deadlines have been extended. While this is certainly well intentioned, I think it is important to remember that it may not exactly be doing anyone a favor. 

Just because you extend the enrollment deadline, does not mean that business will be processed in time to deliver the highest quality of enrollment service.  The insurance companies will likely now bear the brunt of complaints when individuals don't have bills, ID cards or are unable to pre-certify procedures.  Clients who enrolled two days ago are calling and wondering why they don't show up in the system.  Procedures can't be preauthorized so individuals are unsettled about the financial repercussions down the road. 

Surely all this will get sorted out in the long run, but in the interim it is creating double the work for all parties involved. So once again, I advise our readers that patience is going to be key to working with this system in the next several months.  

More importantly, I advise anyone who has not enrolled to use the first two weeks in January to review your options and make your decisions.  The current deadline for Feb 1, enrollment is January 15th.  For the sake of all parties involved, I hope that we will hold to that deadline.

We finally received Anthem Evidence of Coverage documents this week and I was able to verify the information regarding the Anthem Bronze H.S.A. (Health Savings Account) eligible plan.  The family deductible is an aggregate deductible, not embedded as was being told erroneously by some reps on the Covered CA hotline.  This means that if you insure more than one person, the deductible is now $9000.  Other than well care, no benefits are paid until $9000 in eligible expenses are accrued toward the family deductible. So everyone's claims go "into the pot" toward that deductible. 

If we are writing insurance for a couple, then we write two individual policies so they will each have a $4500 deductible.  This is not possible under the Exchange.  It is required that you have a family plan, so you will now have the $9000 deductible should you enroll through the Exchange, regardless of if you are eligible for Advanced Premium Tax Credit  subsidy or not. 

A few more questions of general interest: 

Q. Must a plan cover an adult child under age 26 if the parent/employee does not want to cover the child?

A. No. There is no federal requirement to keep a child on the parent's coverage to age 26. However, a Qualified Medical Child Support Order or National Medical Support Notice could require a health plan to enroll a child even if the employee refuses to do so voluntarily.

Note that starting in 2014, there will be a fee imposed on individuals who do not cover their dependents as defined in Internal Revenue Code Section 152.