Last week, a client came across required disclosure information regarding the health insurance exchange posted by the State Bar of Wisconsin. The three disclosures outlined how to inform employees of the exchange and their options by the March 1, 2013 deadline. Wait a minute. How can employers notify their employees on an exchange that doesn’t exist yet?
This notification date question was asked at the recent Business Day in Madison 2013. The business leaders in attendance were informed that the rulings are still being debated. The Wisconsin Office of the Commissioner of Insurance needs updates from the Health and Human Services (HHS) on the exchanges and the appropriate notification deadline for employers.
In an email newsletter to their agents, United Healthcare said the deadline for employers to notify employees of the availability of Health Benefit Exchanges has been delayed from March 1, 2013, to late summer or fall of 2013. They state the Department of Labor is considering providing generic language that could be used to satisfy the notice requirement. This notice would be coordinated with HHS’s educational efforts (so we are back to waiting on the HHS again).
In a nutshell, employers need to know the “Exchanges” do not exist yet and insurance providers are trying to create their own plans under the same name. The use of the word “exchange” to describe the Federal Government’s plan and the private plans are confusing to consumers!
Anthem (Blue Cross/Blue Shield) started their own exchange earlier this year. Network Health is now promoting that they will be forming their own exchange as well. What this will mean and how these carriers with their own exchanges will integrate with the Federally-run exchanges in Wisconsin is still mostly speculation from all viewpoints.
So if you hear of anyone trying to get you into an exchange early, it’s a play on words. What it means is that agents are selling individual health plans with HRA wrap-around reimbursements, or a defined contribution health plan that is not a group plan, but individual health insurance plans. Our concern is that “exchanges” will continue to mean different things to different people, just like “navigators” and “marketplaces”.
So, when is the exchange coming? When do employers have to tell employees? At least we know it will be fall 2013 at the earliest. We have some time to do what we do best: run our businesses.