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Horman Actuarial Solutions

2021 Updates to Mental Health Parity Testing Requirements

The Consolidated Appropriations Act, 2021 (more here) amended The Paul Wellstone and Pete Domenici Mental Health Parity and Addiction Equity Act of 2008 (MHPAEA) to require group health plans and insurers to perform, document, and disclose comparative analyses of the design and application of non-quantitative treatment limits (NQTLs) for mental health/substance use disorder (MH/SUD) benefits in the plan.  Group health plans and insurers must make this analysis available to Departments of Treasure, Labor, and HHS beginning Feb 10, 2021.  The comparative analysis must demonstrate that the processes, strategies, evidentiary standards, and other factors used to apply NQTLs to MH/SUD benefits are comparable to, and applied no more […]

By |2021-10-29T07:41:03-04:00October 21st, 2021|Regulatory|

An Overview of the Biden Plan to Protect and Build on the ACA

President-Elect Joe Biden has a new health insurance plan for America once he is inaugurated as President on January 20th.  He plans to build on the existing Affordable Care Act as opposed to creating an entirely new plan.  Below is a synopsis of The Biden Plan to Protect and Build on The Affordable Care Act.

  • Expand eligibility for tax credits for more than 400% of poverty level (current limit)
  • Calculate tax credits based on Gold Plans (currently based on Silver)
  • Capping premiums at 8.5% of family income (currently 9.86%)
  • If a family is covered by an employer plan but the individual marketplace plan would be less (due to […]
By |2021-10-21T16:37:26-04:00January 14th, 2021|General|

COVID-19: OCR Issues New HIPAA Guidance for Contacting Recovered Patients

The United States Department of Health and Human Services Office for Civil Rights (OCR) issued updated guidance regarding contacting former COVID-19 positive patients about blood plasma donation, as related to the Health Insurance Portability and Accountability Act of 1996 (HIPAA) privacy protections.  The guidance allows healthcare providers and covered entities to use protected health information (PHI) to identify and contact former COVID-19 positive patients to provide information on donating blood plasma to treat patients with COVID-19, as long as the information is not used for marketing purposes (“marketing” as defined by HIPAA).

Changes to HIPAA Privacy Rule

The HIPAA Privacy Rule allows covered entities or their […]

By |2020-10-02T17:05:08-04:00September 10th, 2020|Regulatory|

How the CARES Act Affects Health Care

On March 27, 2020, Congress passed the Coronavirus Aid, Relief, and Economic Security (CARES) Act to provide $2.2. trillion in federal funding in response to the COVID-19 global pandemic. These funds are available to small businesses, individuals, gig and freelance workers, retail and restaurants, hospitals and public health organizations, as well as large corporations and educational organizations.  While the majority of the relief is to individuals and businesses, a portion of these funds are directed towards expansion of health care delivery in response to the crisis. This Act follows two other pieces of legislation, The Families First Coronavirus Response Act (FFCRA) and an emergency funding bill.

The CARES Act […]

By |2020-09-10T16:55:26-04:00April 9th, 2020|Regulatory|

Summary of The American Health Care Act

This summary is written using the House Ways and Means Committee’s summary and the Kaiser Family Foundation sources.  This bill repeals the Patient Protection and Affordable Care Act and the health care provisions of the Health Care and Education Reconciliation Act of 2010, effective January 1, 2016.  This bill has several steps to move through before it becomes law.  The two bills that compromise the AHCA were introduced into the House Energy and Commerce Committee and the Ways and Means Committee and passed both on March 9, 2017.  The bill next goes to the House Budget Committee then the Rules Committee before going for a vote on […]

By |2020-09-10T16:56:03-04:00March 21st, 2017|Regulatory|

SCOTUS Sides Against Vermont

The Supreme Court ruled 6-2 on March 1st that self-insured employee plans cannot be forced to disclose to the state data regarding what they pay in medical claims (Gobeille v. Liberty Mutual Insurance Co. No. 14-181, March 1, 2016). SCOTUS decided that Vermont overreached in contradiction of federal reporting requirements in trying to gather and analyze the claims data from Liberty Mutual’s self-insured employee plan. Justice Kennedy, writing for the court, said that Vermont’s reporting law was inconsistent with federal goals of a “uniform national scheme” for collecting claims data. Vermont had argued that they needed the data from all payers, including self-funded employee plans, in order to […]

By |2020-09-10T16:56:13-04:00May 12th, 2016|Regulatory|

Who’s to Blame for the High Cost of Healthcare?

It is quite common for a politician to point fingers at who is to blame for the rising cost of healthcare. In addition, policy holders have to fork over a huge portion of their monthly salary for coverage they may never use. I am not writing to politicize the issue or as a consumer advocate (not that I am against that concept), rather I am trying to identify a method to truly understand the cost of the healthcare to society, identify who really is to blame, and form an opinion on what each can do to stem the rising tide.

Understanding the cost of health care

The cost of healthcare […]

By |2020-06-02T16:54:08-04:00February 8th, 2016|General|