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COBRA Subsidy Extension Included in Defense Appropriations, Awaiting President's Signature
Eligibility for the 65% premium subsidy applicable to COBRA continuation coverage provided by group health plans, which was set to expire on December 31, 2009, has been extended as part of the Defense Appropriations Bill of Fiscal Year 2010 (the "Appropriations Bill" ). The House voted to pass the Appropriations Bill, including the COBRA subsidy extension, on December 16, 2009, and the Senate followed suit on December 19, 2009. President Obama is expected to sign the Bill into law prior to the New Year's holiday.
The Appropriations Bill extends by two months the timeframe during which involuntarily terminated plan participants can become assistance eligible individuals (AEIs). Under this extension, an involuntarily terminated individual whose COBRA qualifying event occurs on or before February 28, 2010 is eligible to receive the 65% premium subsidy. The Appropriations Bill also makes the following important changes:
- Extends the COBRA subsidy period from 9 months to 15 months for all AEIs;
- Requires notification of the availability of the new 15 month subsidy period to all individuals who were AEIs on or after October 31, 2009 and all plan participants whose employment was involuntarily terminated after October 31, 2009;
- Requires the 15 month subsidy period be provided to AEIs whose initial 9 month subsidy period has already expired, and requires reinstatement of coverage that may have lapsed due to nonpayment of premium after expiration of the initial subsidy period; and
- For AEIs who overpaid premium due to the expiration of the initial 9 month subsidy period, requires plan sponsors to either offset future premiums in the amount of the overpayment, or provide refunds.
Group health plans must issue special notices related to the COBRA subsidy extension no later than 60 days after enactment of the Bill. In addition, the Bill provides to AEIs whose coverage terminated due to nonpayment after expiration of the initial subsidy period a minimum of 60 days from enactment to pay retroactive premiums to reinstate coverage.
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Is Your Health Risk Assessment In Compliance?
Employers providing incentives in the form of reduced premiums or other forms of financial rewards in return for the completion of a health risk assessment questionnaire may need to revisit their programs. The Genetic Information Nondiscrimination Act of 2008 (GINA) was passed to protect Americans against discrimination based on their genetic information as it relates to health insurance and employment.
Recently issued GINA guidelines prohibit health plans and employers from providing any financial incentives to employees for participating in a health risk assessment that requests information regarding family medical history. The rules apply to group health insurance plans that begin on or after December 7, 2009.
Many employers offering health risk assessments often include both biometric testing and a personal health questionnaire to be completed in order to receive a particular incentive. Many of the health appraisals ask questions regarding an individual's family health history of certain types of cancer, diabetes, heart disease, and other conditions. Most wellness programs have used this type of family history data to further stratify the risk of a participant. For example, a male participant with elevated levels of cholesterol may be deemed at a higher health risk if he has a parent who has suffered a heart attack or been diagnosed with heart disease. Under the new regulations imposed by GINA, employees will no longer be obligated to answer these types of questions; in fact, employers can be penalized for requiring employees to answer these questions as part of a wellness program incentive.
An easy fix to the GINA stipulations regarding incentives and health risk assessments, would simply be to remove the questions related to family history. If this is not possible, instructing employees to not answer them or to only answer them voluntarily will provide a solution. In either scenario, employers with an incentive tied to the completion of a health risk assessment, would be prudent to review the current questionnaire for any family history questions and to have an attorney review the incentive structure for compliance.
More information regarding GINA and how it may impact your wellness program rewards can be found at www.genome.gov/24519851.
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Health Risk Management
As employers continue to look for ways to mitigate health care costs, wellness programs top the list of interventions to consider. Do wellness programs work? The industry data seems to suggest they do, but with some caveats. For example, successful programs require high participation, typically achieved through meaningful incentives. Other characteristics of best-in-class programs include leadership support, an analysis of individual and corporate risk, appropriate interventions for identified risk, an emphasis on keeping the healthy population healthy, and a commitment to analyzing outcomes.
One could say that success with wellness lies not only in program design and execution, but is contingent upon wellness as a component to an overall Health Risk Management (HRM) strategy. If you have a wellness program at your business or are contemplating one, is it part of a greater vision, or is it the strategy? Organizations that have experienced improved health and productivity through wellness share several key characteristics-the most important commonality being that wellness is not in and of itself the strategy, but rather a part of an integrated approach that places emphasis on HRM.
In many instances, wellness programs have operated in a silo with little or no connectivity to the other benefits offered, like short and long-term disability, workers' compensation, employee assistance programs, and disease management, with little or no consideration of the employer's corporate culture. Viewing wellness as part of an overall HRM approach requires an organization to acknowledge that employee health and productivity outcomes are best achieved when all benefits are integrated. This is no easy task, because the employer's health carrier or third party administrator, wellness provider, disease management vendor, and other benefits providers have to be viewed as business partners in the process, willing and eager to share data with one another for a common purpose-improving employee health and productivity.
While the business partners of the employer play a key role in attaining an effective HRM strategy, the employer is in the driver's seat for setting the tone and vision through its workplace culture. The significance of an employer's workplace policies and practices in promoting a culture of health and wellness cannot be overstated.
Take, for example, an employer that places an emphasis on tobacco cessation by providing tools and resources to help people quit using tobacco, but doesn't have a tobacco-free workplace policy or provide for tobacco cessation medications within the health plan. Those who wish to quit find themselves in an environment not supportive of change. On the converse, an employer that has an effective HRM strategy has carefully crafted a tobacco free workplace policy, reviewed all of the tobacco cessation resources offered by its business partners and within the community, aligned the employer-sponsored health plan with the goal of removing barriers to tobacco cessation, like covering pharmacy aids for tobacco cessation, and actively promoted the benefit to its members.
HRM involves a proactive focus on improving employee health and productivity through integrated benefits. It requires business leaders to view the health of the workforce as vital to the overall success of the organization. It also necessitates that the culture within the workplace is one that values and promotes healthy lifestyles.
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Seasonal Influenza & H1N1
Seasonal influenza and the newly identified H1N1 strain of flu virus have dominated the news the last several months. As the flu season continues, it is increasingly important to prepare the workplace for how to prevent the spread of these viruses. According to a recent study published in the journal, Vaccine, the direct medical costs annually for flu average $10.4 billion. Indirectly the flu costs employers approximately $76.7 million a year in absenteeism, presenteeism, and other indirect costs.
Influenza is a contagious respiratory illness cased by influenza viruses. H1N1 is also an influenza virus, but a different strain. The symptoms for both seasonal flu and H1N1 are similar and include fever, cough, sore throat, runny or stuffy nose, body aches, headache, chills, and fatigue. Stomach symptoms such as nausea, vomiting, and diarrhea may also be present.
Employers can be instrumental in helping prevent the spread of flu by educating employees on where they can be vaccinated and how coverage applies under the employer-sponsored health plan. In addition, posting tips on how to protect oneself from the flu, placing hand sanitizer in common places, and encouraging sick employees to stay home are recommended. Listed below are some tips for preventing the flu as well as tips for what to do if flu is suspected.
Tips for prevention:
- Cover your nose and mouth with a tissue when you sneeze or cough.
- Wash hands frequently with soap and water. Alcohol-based hand sanitizer can be used as well.
- Avoid touching your eyes, nose, and mouth.
- Avoid close contact with sick people.
- Throw away tissues and other disposable items used by sick individuals.
- Clean surfaces with household disinfectant.
Tips when you are sick:
- Get plenty of rest and fluids.
- Stay home and minimize exposure to others.
- Call your physician if fever is over 100° F.
- Avoid travel or work for at least 24 hours after fever has subsided.
More information about the seasonal flu and H1N1 can be found at the Centers for Disease Control and Prevention website at www.cdc.gov. The US Chamber of Commerce has also prepared a flu preparedness guide that can be found at www.uschamber.com.
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