What Do PPACA Standards Mean for Employers’ Health Plans? | Towers Watson - Towers Watson

 

Large employer and self-insured plans

Employers with 101 or more employees may not purchase coverage for their employees through the state insurance exchanges, at least until 2017.⁶ Employer plans need not cover all 10 essential benefits or classify their plans into actuarial value tiers. Nevertheless, the PPACA requires large-employer-insured plans and all self-insured plans, whether offered by large or small employers, to meet similar standards for benefit generosity and plan affordability:

1. Actuarial value: Under the PPACA’s employer pay-or-play mandate, employers with 51 or more full-time employees must offer at least one plan with an actuarial value of at least 60% or face potential penalties. Employees of large firms that fail this “minimum value” standard may become eligible for federal premium assistance tax credits to buy coverage in the exchanges. When employees qualify for these credits, the employer must pay a penalty of $2,000 per full-time employee or $3,000 per full-time employee receiving a premium assistance tax credit, whichever is less. Large firms that do not offer a health plan to all full-time employees also face a penalty of $2,000 per full-time employee.⁷
2. “Core” benefits: Most plans offered by large employers already include benefits similar in scope to the 10 statutory essential health benefits, but the law does not require large-employer-insured plans or any self-insured plans to satisfy this standard. The Internal Revenue Service (IRS) has proposed basing actuarial value calculations for these plans on four “core” categories of health services: physician and midlevel practitioner care, hospital and emergency room services, pharmacy benefits, and laboratory and imaging services.⁸ The four core categories include 95% of the charges covered by a benchmark plan with broad coverage.⁹ In practical terms, this difference is likely to have little material impact on actuarial value estimates.
3. Employer premium contributions: Employees of large firms that offer coverage meeting the minimum value standard are not eligible for premium assistance tax credits or cost-sharing subsidies in an exchange unless their share of the employee-only premium in the employer’s lowest-cost plan exceeds 9.5% of family income. Employers whose coverage does not meet this affordability standard must pay the same financial penalty as firms that fail the minimum value requirement. The IRS proposed regulation applied the affordability standard only to single coverage, but the final regulation suggested that future guidance will address family affordability. The regulation could make nonemployee family members eligible for premium tax credits where the self-only coverage is affordable but the family coverage is not.

How do current employer plans compare with exchange standards?

Figure 1 depicts key cost-sharing provisions for prototypical plans that might be offered in the four exchange tiers in the individual market. These plan designs are largely similar to plans that employers currently offer with the exception of the bronze plan, which has considerably higher cost sharing than most current employer plans. The $3,000 deductible is about $1,100 higher than the average deductible for an account-based health plan (ABHP) in 2010.¹⁰ The PPACA might cap deductibles for all employer-sponsored plans at $2,000 (see sidebar), potentially making it difficult for employers to design a plan with a 60% actuarial value.¹¹

Figure 1. Prototypical health plans in each exchange tier

What Do PPACA Standards Mean for Employers’ Health Plans? | Towers Watson - Towers Watson

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