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GAO releases report on employer-sponsored coverage in the ACA

Posted on August 14, 2012 | No Comments

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The Government Accountability Office (GAO) released a report yesterday which reviews estimates of the impact of the Affordable Care Act (ACA) on employer-sponsored coverage. According to some researchers, the ACA’s Medicaid expansion and subsidized coverage for low- and moderate-income people who buy health insurance through Exchanges beginning may discourage employers from offering coverage. However, other researchers believe that the financial penalties imposed by the ACA will actually encourage employers to offer coverage. The GAO report examines 27 studies published between January 1, 2009 and March 30, 2012 that offer estimates regarding changes in employer-sponsored health coverage as a result of the ACA.

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According to a study recently released by the Urban Institute, capping the tax exemption for employer-sponsored coverage could generate $264 billion in revenue by 2023. Limiting the Tax Exclusion of Employer-Sponsored Health Insurance Premiums: Revenue Potential and Distributional Consequences, funded by the Robert Wood Johnson Foundation, recommends capping the top 25% most expensive health benefits to raise this amount. The study finds such an option would lead to a 16% tax increase for those who file taxes in 2014, and a 20% increase for those who file in 2023.
The Robert Wood Johnson Foundation and State Health Access Data Assistance Center released a report finding that 60% of all insured Americans receive insurance through their work. This percentage is down from 70% in 2000, indicating a difference of 11.5 million individuals. The study notes that the decrease in receipt of employer coverage began prior to the 2010 implementation of the Affordable Care Act (ACA), and is caused by a combination of employers no longer offering coverage and employees no longer accepting it. Rising insurance costs is identified as the culprit responsible for the decline of employer-based health insurance.
According to a U.S. Census Bureau report released this morning, the rate of individuals with employer-sponsored health coverage dropped from 64.4 percent in 1996 to 55.1 percent in 2011. Among the employed population aged 18 to 64, 68.2 percent received health insurance through their own employer or another person’s employer. In addition, 34.7 percent of individuals who did not work received coverage through employment-based health insurance and 43.3 percent of individuals with family incomes less than 138 percent of the federal poverty level were employed by firms offering health benefits. The Census Bureau report uses data from the Survey of Income and Program Participation (SIPP) to examine the characteristics of people with employer-provided health insurance coverage as well as characteristics of employers that offer health insurance.
About one in eight (12.8%) nonelderly Americans with employer coverage switched health plans in 2010. This number is down from one in six (17.2%) in 2003, according to a new national study by the Center for Studying Health System Change (HSC). As was true in 2003, about 5 percent of people with employer coverage switched plans in 2010 because of a job change. However, the proportion of people younger than 65 with employer coverage changing plans for other reasons fell from 12 percent in 2003 to 7.5 percent in 2010, often due to a change in employer benefit offerings. Less than 2.5 percent of workers in 2010, about the same proportion as in 2003, initiated a change in plans to reduce their health insurance costs or to get a better quality plan, such as better benefits or a more desirable provider network. According to the report, these findings suggest that consumer choice plays a relatively small role in health plan switching, with most changes resulting from job changes or changes in employers’ plan offerings. Affordable Care Act (ACA) implementation may create opportunities to increase plan choice among people with employer-sponsored coverage, particularly those in small firms, resulting in more frequent switching of health plans. However, a potential downside of more switching is less stable patient-provider relationships, such as in a medical home.
According to a new study for the National Institute for Health Care Reform (NIHCR), offering employer-sponsored health insurance will continue to make fiscal sense for businesses employing most workers (81%) now offered insurance. The study found that the economic incentives to offer coverage will remain strong under the Affordable Care Act (ACA) for most larger, higher-wage firms,  but will weaken for small and low-wage employers. These smaller firms are the companies already more likely to drop coverage to due rising costs. Pre-ACA, all businesses had the option to offer health insurance coverage. After 2014, employer premium contributions remain tax exempt, and two new policies will take effect. First,  larger employers that do not offer affordable health insurance will be penalized and second, premium tax credits for lower-income people to purchase insurance in new state exchanges if they lack access to affordable employer coverage will be available. The economic incentive to cover employees is calculated by adding the dollar value of the employer-sponsored insurance tax subsidy and the value of avoiding the penalty for not offering insurance, and then subtracting the value of the premium tax credits that eligible workers could use in an exchange if their employer does not offer coverage. After 2014, the largest firms (500 or more workers) will continue to have a strong economic incentive, with an average incentive of $2,503 per employee. However, the smallest firms (fewer than 50 workers) will face lower economic incentives because they are exempt from the penalty. Certain industries, such as food service, entertainment, agriculture, forestry and fishing, will have less incentive to offer employer coverage, as their workers will be eligible for exchange subsidies. The study draws on data from the 2008-2010 Medical Expenditure Panel Survey.
According to a new Employee Benefit Research Institute (EBRI) report, the uninsured rate shrank for working-age Americans last year. The percentage of non-elderly Americans with coverage increased to 82 percent in 2011, up from 81.5 percent in 2010. Employment-based health insurance coverage rates dropped, however. Although employer-sponsored coverage remains the dominant source of health coverage in the United States, providing coverage for 155.5 million people under age 65 in 2011, the percentage of non-elderly individuals with employer-sponsored coverage has declined every year since 2000.
Annual premiums for employer-sponsored family health coverage reached $15,745 this year, up 4 percent from last year, with workers on average paying $4,316 toward the cost of their coverage, according to the Kaiser Family Foundation/Health Research & Educational Trust (HRET) 2012 Employer Health Benefits Survey. This year’s premium increase outpaced the growth in workers’ wages (1.7 percent) and general inflation (2.3 percent). The 14th annual survey of more than 2,000 employers highlights trends in employer-sponsored health insurance costs and coverage. The survey reveals significant differences in the benefits and worker contributions toward family premiums between firms with many lower-wage workers (at least 35 percent of workers earn $24,000 or less a year) and firms with many higher-wage workers (at least 35 percent of their workers earn $55,000 or more a year). According to the survey, an estimated 2.9 million young adults are currently covered by employer plans this year as a result of an Affordable Care Act (ACA) provision that allows young adults up to age 26 without employer coverage of their own to be covered as dependents on their parents’ plan. That’s up from the 2.3 million in the 2011 survey. The survey also reports that 48 percent of covered workers are in “grandfathered” plans as defined under health reform, down from 56 percent last year.
The Internal Revenue Service (IRS) issued a proposed rule discussing the minimum value of employer-sponsored health coverage and the ability of employees to receive premium assistance tax credits. According to the proposed rule, IRS states that the minimum value would be determined by dividing the cost of certain benefits to the standard population by the cost of all benefits for the population, including employee cost-sharing and plan payments, and converting that value to a percentage. Several values, such as the amount contributed by employer's to health savings accounts, will be considered in determining the employer's share of costs. However, IRS has also proposed that employer contributions to wellness incentive programs does not count toward health plan minimum value. Additionally, the proposed rule also states that employee-sponsored large group plans are not beholden to every essential health benefit category (EHB), nor must they design their plans to mimic the EHB standards that apply to qualified health plans offered in the Exchange. Adherence to the minimum value requirements will prevent employers from paying the employee shared responsibility payment penalties and will render their employees ineligible for premium assistance tax credits in the Exchange.
On Friday, the Internal Revenue Service (IRS) of the Department of Treasury issued a notice of proposed rulemaking (NPRM) addressing the Affordable Care Act's (ACA's) employer mandate. The IRS also released a series of questions and answers, highlighting the key provisions in the NPRM. The 144-page document explains how to determine which companies constitute large employers and which employees qualify as full-time. In the guidance, IRS also said that large employers must offer coverage not only to employees, but to their families as well.  Comments on the proposed rule are not due until March 18, 2013, and a public hearing will be held on the proposal on April 23, 2013. This comment period contrasts the 30-day comment periods imposed on the proposed market reform and essential health benefits rules recently released by the Department of Health and Human Services (HHS).
Last week, the Internal Revenue Service (IRS) issued a notice regarding safe harbor methods that employers may use to determine which employees will be considered as full-time employees for purposes of the shared employer responsibility provisions under the Internal Revenue Code, as added by the Affordable Care Act (ACA). The guidance expands on the previous guidance by including a safe harbor method that may apply to newly-hired employees. The notice provides employers with the option to use a look-back measurement period of up to 12 months to determine whether new employees are full-time employees, without being subject to a payment for this period with respect to those employees. Also last week, the IRS, Department of Health & Human Services (HHS), and Department of Labor (DOL) issued a notice regarding the 90-day waiting period limitation in Public Health Service Act (PHS Act). The PHS Act provides that, for plan years beginning on or after January 1, 2014, a plan or issuer offering group health insurance coverage shall not apply any waiting period that exceeds 90 days.