December 2013

In This Issue • Happy Holidays From the NCMS Plan and MMIC Agency • The Greatly Exaggerated Death of Employer Sponsored Insurance • Notice of Privacy Practices Updated Per HIPAA Omnibus Rule • Actuarial Values Posted • Ask George • “To eat is a necessity, but to eat intelligently is an art” • Did You Know? Nutritional Counseling Visits Covered 100%

Happy Holidays From the NCMS Plan and MMIC Agency

As the year comes to a close, we reflect on our many blessings and we are thankful for the opportunity to serve you and the hundreds of practices across North Carolina that participate in the NCMS Plan.

Peace, joy, and happiness to you and your loved ones this holiday season.

We wish you much success in the new year!

Pictured (L to R): George Fanelli, Diane Irvine, Jason Horay, Aya Wallace, Barry Hill, Gary Bossert, Rachel Eaton, and Nancy Johnson

The Greatly Exaggerated Death of Employer Sponsored Insurance

Since the Affordable Care Act was passed in 2010, much has been written about whether employer sponsored insurance (ESI) will survive. Without question, ESI plays a critical role in the provision of health insurance to millions of Americans, North Carolinians, and specifically medical practices who participate in the NCMS Plan. Medical practices seek advice from us about what to do for their employees and where they should seek health insurance in 2014 and beyond.

A vast majority of employers indicate they will continue ESI in 2014. 94% of employers “definitely will” or are “very likely” to continue offering ESI to their workers in 2014.¹

Employers are not required to offer ESI, but something compels them to do so, and that reason will not change because of the ACA:

- 87% of employers offer ESI to “retain good employees.”²
- 83% of employers offer ESI to “attract employees.”²

Practices need to be concerned about the competitiveness of their practice if they choose not to offer ESI. Competing for top talent in the healthcare industry has never been more difficult. Practices in the NCMS Plan have demonstrated year after year that they care about their employees. Dropping ESI could send a detrimental message of “you’re on your own” and could alienate staff.

But what about the Exchange and sending employees to www.healthcare.gov for their coverage? Won’t our practice and our employees be better off if we don’t have to deal with health insurance anymore and they get affordable coverage through the Exchange?

Currently, practices receive favorable tax treatment for ESI. Both the employer and the employee benefit from the tax deductibility of ESI premiums. But what happens if you no longer offer ESI and instead give your employees more money to purchase their coverage through the Exchange?

Yes, you could increase employees’ wages by an amount equal to what you are paying for ESI now, but
• that increase becomes taxable wages to the employee, decreasing their purchasing power with those same dollars, and
• that decrease in the employer’s ESI premium payment increases their corporate tax liability, too.

Additionally, one of the touted features of the Exchange is its ability to match enrollees up with appropriate subsidies and credits. However, by increasing the wages of employees, you may inadvertently make them ineligible for the very subsidies and credits that make Exchange coverage affordable.

Higher paid employees of a medical practice are likely the most difficult and costliest to replace. The higher paid employees are also, probably, older employees for whom the cost of coverage is higher, and based on their salary, unlikely to be eligible for Exchange subsidies. If faced with the choice of employment with a practice without ESI and a practice with ESI, the latter is likely the more attractive option. Higher paid workers (e.g. doctors, nurses, PAs, etc.) are better off with ESI and receiving the pre-tax deductibility of their premiums.

So, hypothetically, let’s say you’ve dropped ESI and your employees are covered by the Exchange, now what? Well, the Exchange rates were initially set based on an actuarial projection of what likely costs will be incurred by those who enroll. But, at this point, who knows who and how many will enroll? What if the rates on the Exchange were too low to begin with? If hordes of uninsured suddenly get Exchange coverage and begin receiving care (which is a good thing), the cost is likely to drive up rates. Possibly driving rates back up to the point where ESI is, again, the better cost option. Once a practice has dropped ESI, it will be very difficult to “herd the cats” back into a group plan.

The ACA has created options and opportunities never before available. When making decisions that significantly impact an employee’s health care and an employer’s bottom line, you must think carefully about changes that are difficult, if not impossible, to undo.

The NCMS Plan and its agent consultants are here to serve North Carolina medical practices and to help them navigate these decisions. Hundreds of practices have trusted the NCMS Plan for more than 15 years with their ESI, and we remain a stable and reliable partner.

¹ International Foundation of Employee Benefit Plans, 2013 Employer-Sponsored Health Care: ACA’s Impact (Brookfield, Wisconsin: International Foundation of Employee Benefit Plans, May 2013).
² Deloitte, 2012 Deloitte Survey of U.S. Employers: Opinions about the U.S. Health Care System and Plans for Employee Health Benefits (Washington: Deloitte, July 2012).

Notice of Privacy Practices Updated Per HIPAA Omnibus Rule

As most of our participating practices are well aware, the final amendments to HIPAA resulting from the HITECH Act are now in effect. Compliance was required by September 23, 2013. Every HIPAA "Covered Entity" is required to have a Notice of Privacy Practices (NPP) that accurately reflects patient (or members in the case of the NCMS Plan) rights and practices at the entity. The NCMS Plan, as a health plan, is a covered entity as defined by HIPAA.

The NPP must include the following:

- How the covered entity may use and disclose protected health information about an individual.

- The individual’s rights with respect to the information and how the individual may exercise these rights, including how the individual may complain to the covered entity.

- The covered entity’s legal duties with respect to the information, including a statement that the covered entity is required by law to maintain the privacy of protected health information.

- Whom individuals can contact for further information about the covered entity’s privacy policies.

The changes to the NPP include, but are not limited to, the following:

- Breach notification obligations.
- Description of uses and disclosures.
- Prohibition from using or disclosing PHI that is an individual’s genetic information for underwriting purposes.

The updated NPP can be found at http://www.ncmsplan.com/wp-content/uploads/2013/09/130923-NCMS-Plan-Notice-of-Privacy-Practices-final-v-9.23.13.pdf and a hard copy can be provided upon request.

Actuarial Values Posted

The Affordable Care Act establishes four levels of coverage based on the concept of “actuarial value,” which represents the share of health care expenses a plan covers for a typical group of enrollees. As plans increase in actuarial value – bronze, silver, gold, and platinum – they would cover a greater share of enrollees’ medical expenses overall, though the covereage details could vary across plans.

Since NCMS Plan coverage is available exclusively outside the Exchange, the metal-tier plan levels are not directly relevant. However, as members hear such terms as they relate to the Exchange, understanding how such plans correspond to their coverage in the NCMS Plan is important to compare apples to apples, so to speak.

We have developed an Actuarial Value chart (posted here) for all NCMS Plan health products along with a chart showing the metal-tiers and their corresponding Actuarial Value ranges. With this additional information, you can approximate the value of your NCMS Plan coverage in terms of a metal-tier.

Ask George

Question: George, in addition to the support you provide our practice, does the NCMS Plan have a dedicated service representative at BlueCross BlueShield of North Carolina (BCBSNC), the NCMS Plan’s health plan administrator?

Answer: You’ll be pleased to know that yes, indeed, there are dedicated NCMS Plan contacts at BCBSNC that you can reach out to directly. Many of our practice managers have worked with DeAngelo Dykes in the past. Recently, DeAngelo was tapped for a special assignment within BCBSNC, a testament to the quality of service DeAngelo provided to our practices over the years and we thank him for his service. As a result of this change, we now have new service representatives working on our behalf.

For general service issues such as adding employees/dependents, terminating employees/dependents, name changes, address changes billing and routine maintenance, please feel free to contact Chris Pierce at (919) 765-2515 or email Chris at ncms@bcbsnc.com. Changes can also be sent directly to Chris via fax at (919) 765-3564. In the event that Chris is not available, Carla McCoy can be contacted at (919) 765-3256 (e-mail and fax are the same).

Please note that neither Chris nor Carla can assist with claim status or similar customer service requests. For this, please contact BCBSNC Customer Service at (877) 258-3334.

As always, you can contact me directly with an inquiry at (919) 878-7561 or george.fanelli@mmicnc.com.

“To eat is a necessity, but to eat intelligently is an art”

What you reach for when you need a midday snack can make the difference between staying at a healthy weight and putting on unneeded, unhealthy pounds. The NCMS Plan encourages you and your employees to create healthy eating habits this holiday season. Recently, the NCMS Plan sponsored a Healthy Smoothie Break at the North Carolina Medical Society 159th Annual Meeting. The healthy fruit smoothies were offered between sessions and proved to be a hit among attendees.

Did You Know? Nutritional Counseling Visits Covered 100%

Did you know the NCMS Plan covers nutritional counseling visits, which may include counseling specific to achieving or maintaining a healthy weight? There is no limit to the amount of nutritional visits during the benefit period. As long as the nutritionist is an in-network provider, the session is considered to be a preventive service covered at 100%. To search for an in-network provider, log in to Member Services at http://www.bcbsnc.com/, and click on Find a Doctor.

Have you considered implementing a wellness program that addresses nutrition and overall healthy eating? The NCMS Plan continues to work closely with participating practices to implement a comprehensive wellness strategy that works. Contact Jason Horay, Health Promotion Coordinator at jason.horay@mmicnc.com, to learn more about creating or enhancing your practice's wellness program, using proven strategies, at no additional cost to participating practices.

Let's work together to create a healthier future for your employees.

About the North Carolina Medical Society

Established in 1849, the North Carolina Medical Society (NCMS) is devoted to representing the interests of physicians and protecting the quality of patient care as the largest physician organization in the state. The NCMS Plan, sponsored by the NCMS, is the only statewide employee benefits plan designed specifically for North Carolina physicians.

For more information about many other benefits of NCMS membership, visit http://www.ncmedsoc.org/.