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We hope that you find this month's newsletter informative and helpful. Please feel free to contact your account manager should you have any questions concerning the articles below.

National Health Care Reform: BCBS of MA Updates

Effective September 23, 010, Blue Cross Blue Shield of Massachusetts small group businesses (50 lives and under) will be impacted with the following updates to comply with the National Health Care Reform:

1) Lifetime Limits
BCBS of MA will be removing lifetime limits from Specific Indemnity and all POS plans that that currently have a lifetime limit due to the NHCR rule of group and individual health plans and insurers are prohibited from establishing lifetime limits on essential benefits for any participant or beneficiary.

2) Annual Limits
BCBS of MA will be removing annual limits on essential services that currently apply an annual limit. This provision applies to all insured and self-insured medical accounts due to the NHCR rule of only "restricted" annual limits on the dollar value of essential benefits are permitted.
The plans that will be impacted are specific Blue Care Elect and Indemnity Plans.

3) Preventive Care with No Cost Sharing
BCBS of MA will be removing the copayment from preventive health services on standard in network plans that currently apply a copayment due to the NHCR rule of group health plans and insurers may not impose cost sharing for preventive coverage. This rule does not apply to our of network plans. Preventive services include the following:·

• Preventive Pediatric Care: OV, Lab tests, Immunizations
  
• Preventive Adult Exams: OV, Lab Tests, Immunizations, Lead Screening, Routine Mammograms and PSA tests
• Routine GYN Exams: OV, Routine Pap Smear test
• Family Planning
• Routine Hearing Exams: OV, Newborn Hearing Screening Test and Hearing test
• Routine Vision Test
• Prenatal Care
• Well Newborn Care (inpatient)

Please be advised that these rules are subject to change at any time. PBG will notify you of any changes related to the National Health Care Reform.

Centers for Medicare and Medicaid Services Update HRA Reporting Requirements

The Centers for Medicare and Medicaid Services (CMS) recently released an updated Group Health Plan User Guide related to the Medicare Secondary Payer Mandatory Reporting requirements applicable to group health plans. The new rules dictate when a group plan must pay claims as the "primary insured" for an employee or the employee's spouse or eligible dependent if that individual is covered by both the plan and Medicare.

Among the issues addressed in the updated guide are references to changes in reporting for Health Reimbursement Arrangements (HRAs). CMS has removed all references from the updated guide that previously referred to reporting only for "free-standing" HRAs. Prior versions of the guide also referenced "imbedded coverage" as HRA coverage that was part of a more comprehensive or standard group health plan that need not be separately reported.

All HRA coverage must now be reported by the "responsible reporting entity" (RRE) if it otherwise meets the reporting requirements, regardless of whether the HRA is considered to be "imbedded" or "freestanding" coverage. If a group plan provides both standard coverage and HRA coverage, then the RRE may need to submit two records to CMS - one for the standard coverage and one for the HRA coverage.

Note that RREs are not required to report HRA coverage retroactively. Instead, HRA coverage must only be reported for coverage effective on or after October 1, 2010. In addition, the guide stipulates that only HRA coverage which reflects an annual benefit value of $1,000 or more is to be reported. Therefore, HRA coverage with an annual benefit amount that totals less than $1,000 will be exempt.

Adult Child Health Plan Coverage Interim Rules Announced under the Affordable Care Act

Beginning this September, children will be allowed to stay on their parents' group health plan until age 26, even if they no longer live with their parents, are no longer tax dependents, are married, or are not enrolled as full time students. And beginning in 2014, children up to age 26 may also stay on their parents' plan even if offered coverage through their own employer. This extension of coverage for adult children is mandatory for group health plans as of the first plan year beginning on or after September 23, 2010. (This does not apply to grandfathered group health plans until 2014.)

New transition regulations also apply to adult children who lost eligibility before reaching age 26 or were older than the plan's qualifying dependent age when the parent became eligible to participate in the plan. Plans must offer these dependents notice of the coverage availability and an enrollment opportunity lasting at least 30 days, offered no later than the first day of the first plan year on or after September 23, 2010. Plans which voluntarily allow adult children to remain on their parents' plan need not offer a special extended enrollment.

Lastly, adult children who are continuing coverage through COBRA who become eligible for coverage under this transition rule, must be offered the opportunity to enroll as active employees' dependents. When they lose eligibility at age 26, a new COBRA election must be offered.

CLASS: An LTC Alternative

Neither private health insurance nor Medicare covers basic long-term services. This is where CLASS comes in. CLASS (Community Living Assistance Services and Supports) is a federal, voluntary, long-term care insurance program established by the new health care reform law. CLASS will provide a daily cash benefit, at least $50 per day, to insured individuals who become limited in several basic activities of everyday life. CLASS will supplement, not replace, family care, personal saving, private insurance, and Medicaid. CLASS participants must also pay premiums for a minimum of 60 months and have been actively working for at least 3 years of that time, before benefits will become available. All working adults will be eligible to enroll in the program, however it is not mandatory. Late entrants will pay a penalty. Non-working spouses and other non-working individuals are not eligible to enroll.

A Few Reasons You May Need LTC:

• Alzheimer's or Senile Dementia
  
• Parkinson's Disease
  
• Arthritis, Bone Fractures
  
• Depression
  
• Cancer
  
• Diabetes and Heart Disease
  
• Strokes
  

Sincerely,

Maria Eramo
Partners Benefit Group, Inc.

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