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State Issues Regulations on Employer Health Assessment

Posted by Katie Holahan on Nov 6, 2017 4:08:53 PM

The Baker Administration today released draft regulations for the new employer health assessment designed to close a budget shortfall in the state's MassHealth program.

Read the Draft Regulations

The regulations, published by the Massachusetts Department of Unemployment Assistance (DUA), explain details of how the new Employer Medical Assistance Contribution (EMAC) supplement will be administered. The EMAC supplement is a new wage tax, levied on employers who have certain workers enrolled in either the MassHealth program or subsidized Health Connector coverage. 

  1. Employers with six or more employees will access their estimated liability for the EMAC supplement quarterly, via their DUA online account when they provide their quarterly wage filing;
  2. Detailed information will be provided as to the number of their employees on MassHealth or subsidized Connector coverage;
  3. Employers have 10 days from receipt of this information to appeal their determination of liability to the DUA.

The draft regulationsare available for public review and response. The Department will hold five listening sessions, across the state, to allow employers and interested parties to provide in-person feedback:

  • Boston | November 13 | 1-3 pm | Hurley Building
  • Springfield | November 14 | 10 am - nooon | Department of Industrial Accidents office
  • Worcester | November 15 | 2-4 pm | Department of Industrial Accidents office
  • Lawrence | November 16 | 10 am - noon | Department of Transitional Assistance.

A fifth session will be scheduled on Cape Cod.

Questions and suggestions may also be shared with the Department electronically.

 

Topics: Controlling Health Care Costs, Employer Health Assessment

Health Reform Must Address Employer Costs

Posted by Katie Holahan on Oct 24, 2017 11:33:45 AM

Associated Industries of Massachusetts (AIM) is pleased that the state Senate on Monday conducted a hearing on a proposal to address the challenging issue of healthcare affordability. The primary question for AIM in evaluating any such proposed legislation is whether it eases the burden of employers struggling to provide good health insurance to workers.

health_care.jpgIn 2006, employers joined with doctors, hospitals, patient advocates, and lawmakers to forge a health-reform law that required everyone to share the responsibility for improving access to health care. Eleven years later, Massachusetts residents enjoy the highest levels of health-insurance coverage in the nation.

Yet we have failed to make progress to contain the unsustainable increases in health-care costs.

According to the most recent data available from the Centers for Medicare and Medicaid Services (CMMS), Massachusetts was the second highest-spending state for health care in 2014, shelling out 30 percent more than the national average.

Personal health-care spending in Massachusetts, per capita, has increased more than 12 percent in five years – from $9,417 in 2009 to $10,559 in 2014. Cost growth like this is unsustainable and has increased unabated in the face of attempts by both employers and the commonwealth to contain it.

Businesses, in fact, have almost nothing to show in the way of cost savings and efficiencies five years after Massachusetts made a major push toward health-care cost containment in 2012. The commonwealth has exceeded the 3.6 percent spending growth benchmark established as part of the health-cost control law of 2012 in two of the past four measurement periods.

Total Health Care Expenditures (THCE) grew by 4.2 percent from 2013 to 2014, and by 4.1 percent from 2014 to 2015. These cost increases are occurring in an industry in which experts agree that at least one-third of all care is unnecessary – delivered in the wrong setting; marked by a lack of coordination; provided with an inadequate emphasis on prevention; harmed by medical errors; burdened with rules and fraud; or just plain excessive.

Massachusetts employers have strong ideas about some of the policies included in the draft Senate health-reform legislation:

MassHealth Reforms

In a state facing an alarming deficit in its Medicaid program, employers are currently shouldering the escalating costs of the public health-care system. For the next two years, employers statewide will provide at least $200 million annually in funding for MassHealth in addition to the cost of providing commercial health insurance to their workers.

More importantly, employers are being asked to close a funding deficit absent any of the long-term structural reforms needed to solve the underlying financial problems with the program. Action must be taken to improve the efficiency and cost-effectiveness of this currently unsustainable program.

Optional expanded Medicaid plan

AIM must raise grave concerns with the notion of expanding the MassHealth program through an optional Medicaid plan (SECTION 123) without first addressing existing policies that encourage and sustain needlessly expensive health-care habits.

Employers have long sought to contain costs in commercial health insurance by encouraging cost-effective habits like relying on primary care physicians for non-emergency care. The same cannot be said for the MassHealth program. The inappropriate use of emergency rooms is an example of one major cost driver identified by the Health Policy Commission. To contain costs and facilitate coverage, we must address our greatest cost-drivers in health-care utilization across the entire spectrum of both commercial and public health insurance before we implement any sort of further programmatic expansion.

“Name and Shame” List

AIM also opposes the so-called “Name and Shame” list (SECTION 38), highlighting employers with workers in the MassHealth program. The 2006 health-reform law made employees who were offered employer-sponsored health insurance ineligible for MassHealth. The intent was to balance the requirement that employers do their “fair share” with concerns about the financial burden on the MassHealth system.

The Affordable Care Act (ACA) reversed that policy and allowed income-eligible employees to decline employer coverage and seek insurance through MassHealth. The change created a migration of newly-eligible individuals from their employer-sponsored insurance to MassHealth, substantially increasing the commonwealth’s financial burden. The ACA made public health insurance an economically rational choice for eligible residents in a state known for its expensive health-care system.

Provider Price Variation

Provider price variation includes both reasonable and unreasonable variation in the pricing of health care services. Reasonable variation in pricing should be supported and limited by a transparent marketplace in which consumers have access to clear cost and quality metrics. By mandating a minimum increase in provider prices (SECTION 111) without alleviating existing high-cost drivers, we facilitate the continued increase in price variation without seeking to understand and differentiate among the cost-drivers that result in both reasonable and unreasonable price variation.

Innovative Insurance Products

While we support market-based solutions through innovative insurance products like limited and tiered-network products, we are concerned that the differential limitations alone will be insufficient to leverage this new approach. Without a requirement that all providers participate in the contracting for such products, insurers will not always have the negotiating power to construct products in all regions of the commonwealth.

Scope-of-Practice Expansions

AIM supports the various scope-of-practice expansions included in the draft legislation. Expanding access to vital care from qualified providers for all residents of the commonwealth is a common-sense reform that helps to move us closer to a healthcare system that is efficient and effective.

Telemedicine

AIM supports the inclusion of telemedicine services (SECTION 94) to facilitate innovative, cost-effective health-care services for consumers across the commonwealth. Telemedicine services could provide additional care options for consumers with limited access, preserve productivity, and reduce time lost traveling great distances to providers. A vital component of this policy is requirement that payment for telemedicine services cannot exceed the costs related to an in-person visit. We must prioritize innovative policies that both increase access and decrease costs for residents statewide. Telemedicine should and could do exactly that.

AIM-member employers are active participants in providing health insurance to the majority of residents in the commonwealth. Moderating the cost of that insurance and putting health care on a financially sustainable business is critical to the future of the Massachusetts economy.

Please contact me at kholahan@aimnet.org if you would like to be updated on the progress of health reform in Massachusetts.

Topics: Massachusetts senate, Controlling Health Care Costs, Health Insurance

AIM Calls for Long-Term Cost Changes to MassHealth

Posted by Rick Lord on Jul 25, 2017 2:19:20 PM

Editor's note - Associated Industries of Massachusetts President Richard C. Lord submitted the following testimony today to the Legislature's Joint Committee on Ways & Means and Joint Committee on Health Care Financing urging lawmakers to approve long-term structural changes to the state Medicaid program. AIM's Katie Holahan (above) delivered the same message in testimony before the committees.

On behalf of Associated Industries of Massachusetts (AIM) and its 4,000 employer-members statewide, thank you for your continued engagement with the employer community on the difficult issues before you today. We are pleased that both committees have so promptly scheduled this hearing and the second hearing scheduled for this afternoon. 

AIM supports the language contained in Governor Baker’s amendment to the Fiscal Year 2018 budget, returned to you within Attachment F.  The amendment contains a complex agreement that was developed after months of intensive negotiations between the Baker Administration and the business community. We believe the comprehensive plan moderates the proposed employer assessment by coupling it with meaningful structural reforms to the public health insurance system and rate relief within the Unemployment Insurance system.   

It is vital to maintain all aspects of this package so we will not find ourselves addressing an even larger MassHealth budget deficit in two years than the one we confront today. 

AIM likewise supports language authorizing the Baker Administration to seek a federal waiver allowing Massachusetts to return to policies implemented within the 2006 Health Care Reform law, and to expand the scope of practice for certain health-care providers to facilitate lower-cost care. 

The 2006 reform law made employees who were offered employer-sponsored health insurance ineligible for MassHealth.  The intent was to balance the requirement that employers do their “fair share” in offering health insurance with concerns about the financial burden on the MassHealth system.  The Affordable Care Act (ACA) reversed that policy and allowed income-eligible employees to decline employer coverage and seek insurance through MassHealth.  

The change created a migration of newly-eligible individuals from their employer-sponsored insurance to MassHealth, substantially increasing the commonwealth’s financial burden.  The ACA made public health insurance an economically rational choice for eligible residents in a state known for its expensive health-care system.   

As MassHealth enrollment grows, the commonwealth experiences the reality that employers have faced for years: the high cost of health-care coverage in this state threatens the underpinnings of our economy.  Policymakers who have concentrated almost exclusively on access and coverage now face a renewed imperative to lower the cost of health insurance for everyone in Massachusetts. 

AIM member employers are proud to lead the nation in providing health care coverage to their employees. Sixty-five percent of Bay State companies offer health insurance coverage to their workers, compared with 56 percent of employers nationwide. A full 100 percent of Massachusetts employers with 200 or more employees offer coverage.1 

The 4,000 member employers of AIM provide health insurance to the majority of residents in the commonwealth. 

But providing that coverage has financial consequences. 

According to the most recent data available from the Centers for Medicare and Medicaid Services (CMMS), Massachusetts was the second highest-spending state for health care in 2014, 30 percent more than the national average. Personal health-care spending in Massachusetts, per capita, has increased more than 12 percent in five years – from $9,417 in 2009 to $10,559 in 2014. Cost growth like this is unsustainable and has accelerated in the face of attempts by both employers and the commonwealth to contain it. 

Businesses, in fact, have almost nothing to show in the way of cost savings and efficiencies five years after Massachusetts’ major push toward health care cost containment. 

The commonwealth has exceeded the 3.6 percent health spending growth benchmark in two of the past three measurement periods. Total Health Care Expenditures (THCE) grew by 4.2 percent from 2013 to 2014, and by 4.1 percent from 2014 to 2015. 2 

These cost increases are occurring in an industry in which experts agree that at least a third of all care is unnecessary – delivered in the wrong setting; marked by a lack of coordination; provided with an inadequate emphasis on prevention; harmed by medical errors; burdened with rules and fraud; or just plain excessive.  

Now, the employer assessment means that business is expected to shoulder the escalating costs of the public healthcare system, as well.  More importantly, they are being asked to close the MassHealth deficit absent any of the  long-term structural reforms needed to solve the underlying financial problems with the program. 

Eleven years ago, employers joined with doctors, hospitals, patient advocates and lawmakers to forge a health-reform law that required all parties to share the responsibility for improving access to health care. The employer community calls for that same sense of shared responsibility now to solve the MassHealth shortfall. 

Thank you for considering AIM’s views and please feel free to contact me if you have any questions or need any further information.  

Topics: Massachusetts state budget, Controlling Health Care Costs, Employer Health Assessment

Governor Sends Back Employer Assessment; Seeks MassHealth Reforms

Posted by Katie Holahan on Jul 17, 2017 3:38:18 PM

Governor Charles D. Baker returned to the Legislature today the employer health-care assessment portion of the Fiscal Year 2018 budget, along with provisions changing Unemployment Insurance rates for 2018 and 2019, and urged legislators to include long-term reforms that will put the MassHealth program on a firm financial footing.

Health.Energy.jpgThe governor is also filing separate legislation making reforms to the commercial health-insurance market.

“The governor’s actions provide the Legislature with the opportunity to review and vet the reforms, and to pass a thoughtful, comprehensive package that balances investments made by all stakeholders in the Massachusetts healthcare system,” said Richard C. Lord, President and Chief Executive Officer of Associated Industries of Massachusetts.

The employer assessment would raise $200 million annually through the Employer Medical Assistance Contribution (EMAC) and fall most heavily on companies where employees use MassHealth instead of an employer health plan. The assessment would be offset by a two-year Unemployment Insurance rate adjustment that would save employers $335 million over two years versus current rates.

The administration hammered out the MassHealth reforms during months of negotiations with AIM and other members of the business community. The proposed reforms include:

  • Restructuring MassHealth coverage for non-disabled adults to look like commercial insurance coverage;
  • Moving 140,000 people with income above 100% of the federal poverty level out of MassHealth and into ConnectorCare;
  • Shifting 230,000 MassHealth members from standard MassHealth coverage, which includes coverage for long-term care, into CarePlus, which does not;
  • Requiring the commonwealth to petition the federal government to re-establish the prohibition against employees who are offered employer-sponsored insurance from seeking coverage through MassHealth.

The Baker Administration’s decision to file stand-alone legislation addressing commercial health insurance reforms acknowledges the need for comprehensive reform of our private healthcare systems. As employers are faced with the second most expensive health-care costs in the nation, the need for reform and cost containment is vital to maintain both the quality of care and the level of coverage across our commonwealth.

AIM looks forward to the Legislature’s consideration of these challenging topics and their willingness to engage with a broad coalition of partners across our health-care system to attain an equitable resolution.

Topics: Massachusetts state budget, Controlling Health Care Costs, Employer Health Assessment

Governor, Business Community Reach Compromise on Health Assessment

Posted by Katie Holahan on Jun 20, 2017 2:00:00 PM

The Massachusetts business community has agreed to support a broad compromise plan to stabilize the Massachusetts Medicaid and Unemployment Insurance systems while offseting a two-year employer health-care assessment with savings elsewhere.

Baker.2017.jpgThe complex agreement, developed after months of intensive negotiations between the Baker Administration and the business community, would make structural changes to the MassHealth program to reduce ongoing financial shortfalls in the state/federal insurance program for low-income people. There would also be cost-saving changes to the commercial health-insurance markets, including increased incentives for patients to seek care at high-quality community hospitals.

The plan would use a temporary employer health assessment as “bridge financing” to capitalize the MassHealth program until the long-term reforms are implemented. The assessment would raise $200 million annually through the Employer Medical Assistance Contribution (EMAC) and fall most heavily on companies where employees use MassHealth instead of an employer health plan.

The assessment would be offset by a two-year Unemployment Insurance rate adjustment that would save employers $335 million over two years versus current rates.

The administration announced the agreement today in a letter to the chairs of the Legislature’s Joint Committee on Ways and Means.

“The comprehensive plan moderates the employer assessment that was originally proposed in January while offering the opportunity for meaningful structural reforms to the health insurance system and rate relief within the Unemployment Insurance system,” said Richard C. Lord, President and Chief Executive Officer of AIM.

The compromise will require approvals both from the Massachusetts Legislature and from federal officials.

Here are the key elements of the agreement:

MassHealth/Medicaid

  • Moves 140,000 people who are above the federal poverty level out of Masshealth and into the Connector market;
  • Restructures MassHealth coverage for non-disabled adults to look like commercial insurance coverage;
  • Shifts 30,000 MassHealth members from standard MassHealth coverage, which includes coverage for long-term care, into Careplus, which does not;
  • Adds co-pays for MassHealth members;
  • Requires the commonwealth to petition the federal government to re-establish the prohibition against employees who are offered affordable health insurance by an employer from seeking coverage through MassHealth.

Commercial Market Reforms

  • Imposes a five-year moratorium on insurance mandates (requires change to state law);
  • Increases the required premium differential for tiered network plans from the current 14 percent to 28 percent. (requires state law change);
  • Promotes transparency tools for employers and consumers. (requires state law change);
  • Increases access to lower-cost providers by expanding the scope of practice for optometrists, podiatrists and advanced practice registered nurses (APRN) and creating a new mid-level provider - dental therapists. (requires state law change).

Employer Assessment:

  • Applies to employers with six or more employees (both full and part-time);
  • Increases the EMAC contribution rate for all employees, statewide. Additional annual two-tiered assessment on any employees receiving health insurance through public programs.
  • Tier 1 is broad based, raising the current EMAC rate from 0.34 percent to 0.51 percent of annual wages, up to the annual wage cap of $15,000. Applies to all employers currently subject to EMAC; raises the maximum per-employee contribution rate from $51 to $77; state expects to annually collect $75M under this tier;
  • Tier 2 introduces a targeted payment that would require employers to pay an additional 5 percent of annual wages for each non-disabled employee on public coverage, up to the annual wage cap of $15,000; applies to all employers currently subject to EMAC with non-disabled employees on MassHealth (not in premium assistance) or subsidized Connector coverage (ConnectorCare); Tier 2 would result in an annual maximum per employee contribution rate of $750; state expect to collect an estimated $125M in Fiscal Year 2018 under this tier; the estimate is dependent upon the actual number of individuals on public coverage.
  • Waiver applies for anyone receiving insurance through parent, spouse or other household member;
  • Implementation date of January 1, 2018 and a sunset date two years later.

Unemployment Insurance

  • An automatic increase of three levels to schedule F due to take effect on January 1 would be replaced with a one-level jump to schedule D for 2018 and another single increase to schedule E for 2019.

Governor Baker in January proposed to close a $600 million shortfall in MassHealth by levying a $2,000-per-employee fee upon companies at which at least 80 percent of full-time worker equivalents do not take the company’s offer of health insurance, or do not make a minimum contribution of $4,950 annual contribution for each full-time worker. AIM opposed that plan because it would penalize the majority of companies that provide good health insurance to their workers.

Topics: Controlling Health Care Costs, Charlie Baker, Employer Health Assessment

Senate Municipal Plan Design Language Falls Short – Undercuts Savings

Posted by John Regan on Jun 14, 2011 12:31:00 PM

describe the imageAssociated Industries of Massachusetts is asking lawmakers to adopt the House version of a bill giving cities and towns the power to control health insurance costs.

AIM said in a letter to budget conferees that the Senate version of the municipal health measure would undermine the estimated $100 million in savings promised by the bill.

AIM's concern about the Senate bill was confirmed this morning by a study showing that:  “Dozens of communities across the state would lose the benefits of municipal health care reform under the Senate’s provision requiring that municipal contributions for retirees be the same as for active employees, according to a preliminary analysis by the Massachusetts Taxpayers Foundation. The Foundation has identified 50 municipalities and regional school districts that would be impacted, with that number likely to be as high as 100 when all communities have been analyzed.”

Click here to read the MTF analysis.

AIM and Massachusetts employers generally support municipal health reform because the spiraling cost of health insurance is eroding the ability of city and town governments to deliver educational, public safety and other services upon which the economy depends.

Topics: Associated Industries of Massachusetts, Health Care Reform, AIM, Municipal Reform, Controlling Health Care Costs, Senate Budget

Does Your Company Qualify for the Federal Health-Care Tax Credit?

Posted by Kyle Pardo on Jun 8, 2010 3:53:00 PM

More than 102,000 Massachusetts employers may be eligible for the new federal tax credit intended to help small companies cope with the expense of providing health insurance to employees. But how do you know whether or not your company qualifies? How much is the tax credit? And what's in the fine print?

The small business health-care tax credit provision of federal health care reform (Patient Protection and Affordable Care Act, or PPACA) was created to reduce health insurance costs for employers with fewer than 25 full-time equivalent (FTE) employees.  The amount of the income tax credit is graduated based on the number of FTEs, but the maximum for the 2010-2013 tax years is 35 percent of the amount a qualifying employer contributes toward the cost of coverage for its employees. That's real money if you run a small business. 

The IRS recently sent post cards to approximately four million businesses nationwide that may be eligible for the tax credit, including more than 102,000 in Massachusetts.  The tax credit is available to employers meeting all four of the following criteria for tax years 2010 - 2013:

  1. The employer must either be a taxable employer or a 501(c) tax-exempt employer;
  2. The employer must have fewer than 25 full-time equivalent employees for the tax year;

    The definition of one FTE is 2,080 payroll hours per year.

    "Payroll hours" include all hours worked, as well as all hours paid but not worked (vacation, holidays, sick time, jury duty and all other paid absences).

    Seasonal workers may be excluded if they work no more than 120 days in the year. It is important to remember that the definitions of FTE and "seasonal employee" are different under the federal and Massachusetts health care reforms, and many small employers must use both - just one small example of the growing complexity of integrating state and federal requirements.

  3. The average annual wages for each FTE must total less than $50,000, calculated by dividing the total gross wages, i.e., before any deductions are made for taxes, 401(k), benefits, etc., by the number of FTEs; and
  4. The employer must contribute at least 50 percent of the individual premium cost for health insurance provided through a qualifying arrangement.  This is known as the "uniformity requirement."  The definition of "health insurance" includes medical insurance, stand-alone dental plans, stand-alone vision plans, and long-term care plans.  

For purposes of both the FTE and average wage calculations above, certain business owners, partners, and their family members, as defined in IRS guidance, are excluded, i.e., they are not deemed to be "employees."

Read the Full Article

Topics: Associated Industries of Massachusetts, Health Care Reform, Health Care Costs, Controlling Health Care Costs, Health Insurance

Early Intervention & Controlling Massachusetts Health Care Costs

Posted by Eileen McAnneny on Jun 2, 2010 10:00:00 AM

One item passed during the Senate budget debate highlights the dilemma and challenge facing lawmakers in these trying economic and fiscal times.

On the one hand, the Senate has made controlling health care costs for small businesses a top legislative priority for this session. On the other hand, they continue to advance policies that add new costs for the very businesses they seek to help.

Budget Amendment #628 excludes early intervention services from being subject to co-payments or deductibles for coverage offered through a licensed carrier. Early Intervention services are provided to young children from birth until their third birthday. By excluding early intervention services from any type of cost-sharing mechanism, including co-payments and deductibles, employers have less ability to control their health care costs and keep monthly premiums at a minimum through use of innovative benefit design.

While we recognize the value of early intervention services, AIM is not supportive of this measure as it increases monthly premiums at a time when employers are struggling with the high cost of health care, and sets a bad precedent as the Senate works to provide relief to small businesses.

Small- and medium-sized businesses will largely bear this new cost since large, self-insured employers that are governed by the Federal Employee Retirement Income Security Act (ERISA) are not subject to this new mandate.

We cannot make the cost of health care "free" to consumers while thinking we can keep costs down for businesses at the same time. Someone has to pay for the health care consumed.

If patients do not have out-of-pocket expenses, they consume more health care services than they need. This does not lower costs. If businesses must shoulder more of the cost of a particular service, as proposed by this amendment, there will be less money available for other types of health care benefit; less for compensation to employees; and less for investment in the business.

Lawmakers can no longer shield consumers from the true costs of health care. Consumers are key to transforming out health care system into a more rational and efficient one. The policy to disallow cost sharing for early intervention services is a step in the wrong direction and at odds with the Senate goal of reducing health care costs for small businesses.

We hope this language is not adopted in the final budget approved by the Budget Conference Committee and sent to the Governor

 

We hope this language is not adopted in the final budget approved by the Budget Conference Committee and sent to the Governor


Topics: Health Care Reform, Health Care Costs, Controlling Health Care Costs, Senate Budget, Massachusetts, Federal Employee Retirement Income Security Act, Early Intervention Services

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