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April 5, 2010
So.......where are we today? We are still not exactly sure of anything, except we do have health reform and that it will affect your self-funded health Plan (Advantage Health Plans Trust) in the future. How will it affect your Plan? We do not know yet. When will it affect your Plan? There are various proposed implementation dates ranging from 90 days to the year 2018. Be assured, Kempton and your Trustees are watching this every day and evaluating how this might change your Plan. This will be a long, long process, not an event.
We are, and have been for some time, trying to nail down effective dates and what applies to which types of plans. It is quite a challenge as most of these questions are not answered clearly in the legislation as passed. There is so much that is "To Be Determined" by the Secretary of Health and Human Services or some other agency, and that just hasn't happened yet. (Some of these regulatory agencies don't even exist yet.)
We also have many dueling opinions from some of our trade associations telling us that many of these requirements won't affect self-funded plans already in place. We are NOT counting on that, but it is out there. The pre-existing change won't be as big of a deal to most group plans as you might think. We have already had portability without pre-ex since 1997 due to HIPAA creditable coverage. However, that change is going to be hugely destructive to the individual health insurance market. No lifetime maximums is also one I am not really worried about at this point. Advantage Health Plans has a lifetime max of $3 million dollars. Right now, it is just almost impossible to survive that much care. Notice, "almost impossible", not "completely impossible". Myself and some of my staff are heading to DC next week to hopefully get some answers and will be sharing our finding with our clients ASAP.
We do know that there will also be a much increased level of reporting and administration required of most employers. We will be offering those services as the implementation dates arrive. We know you have a business to run and we are here to assist you in being able to focus on that, not health Plan compliance. Please contact your account manager for more information.
Overall, I think Advantage Health Plans Trust is going to come out of this in pretty good shape, as it has always been run in a non-profit (truly) configuration, as opposed to the fully insured insurance companies. We are the good guys in this debate. I don't know of a single client of mine that does not worry about if they are providing a quality benefit Plan to their employees and their families. We will keep you informed, but don't hesitate to contact me or your account manager if you have any questions.
Jay W. Kempton
President & CEO, The Kempton Company