As I sit down to jot my thoughts on some encouraging news relative to individual and family health insurance plans in Pennsylvania, it is not lost on me that most of us who have worked in this segment thought we were long ago left in the dust, just like the customers we serve. However (and yes, here it is... the paradigm shift), with the 2016 relatively modest release of the Qualified Small Employer Health Reimbursement Arrangement (QSEHRA) and the 2019 Individual Coverage Health Reimbursement Arrangement (ICHRA), along with Pennsylvania's move to a State Based Exchange (SBE) for January 1st 2021 enrollments, I think the individual and family health insurance market is worthy of some renewed moments of serious contemplation.
Small employers are still struggling with the pricing model, both in cost to bottom line, and cost to retain more seasoned and more experienced employees in this strong job market. Is QSEHRA the answer for some small employers? YES, based on my experience and in my opinion only.
QSEHRA's were not widely embraced. Remember, QSEHRA's are employer offerings with products within the individual and family segment. We can discuss why the confusion, the clunky set-up, the additional costs of the administration, and the fact that the individual plans were not attractive and often more expensive than group plans could have affected their popularity… but let's move on.
QSEHRAs allow employers in the 2-50 market to remove themselves from the group health platform and offer reimbursement for employees that seek subsidized or unsubsidized individual or family coverage.
As of January 1st 2020, the Individual Coverage HRA (ICHRA) offers employers of all sizes a platform to have a hybrid of group health offerings and individual/family health offerings. The ICHRA answers the question on how to best serve all segments of employees that might benefit by coverage within the individual and family markets, such as out-of-state employees that need a different provider network, salary or hourly employees, unionized employees, etc.
This platform truly does offer a great deal of creativity within one group while compliantly meeting both employer and employees' needs with a combination of group health and individual products.
And if you need another reason that the QSEHRA and/or ICHRA are worth getting reacquainted with, Pennsylvania is moving to a State Based Exchange (SBE) for January 1st 2021 enrollments so you should definitely re-educate yourselves.
With Pennsylvania purchasing an online platform via GetInsured to facilitate enrollments for 2021, we no longer have to enroll, or correspond with, any portion of healthcare.gov. Not the website, not the Navigators, not the Assisters, not for changes, and most especially not for problem resolution. Dare I say it could be easier to do business in this segment in 2021? That's my hope.
It's also less costly for the health insurance carriers and the Commonwealth to offer this platform, and allows Pennsylvania more innovation with reinsurance dollars to bring down premiums for those that aren't eligible for premium subsidies.Let's take a quick trip down memory lane to review how we began down this path with the Affordable Care Act:
- ACA Law signed March 23, 2010
- We were to save up to $2,500/household
- Healthcare.gov was to be as easy as purchasing airline tickets or hotel reservations
- Tax penalty for first enrollment year enforce, 2019 and 2020 tax penalty is zero
- Carriers reduced and/or removed compensation
Make your voice count
Now, if you're still following along, I ask you to stick with me on this journey because I have been named by my colleagues in the Pennsylvania Association of Health Underwriters (PAHU) to serve as their seat for the Pennsylvania Health Insurance Exchange Authority (PHIEA) Advisory Board to offer insight and advice that can benefit all of us!
Alone, all of these new market opportunities will not be successful if our Pennsylvania Insurance Department and the Pennsylvania insurance carriers do not buy-in to the partnership with licensed and certified brokers in our Commonwealth to re-educate, re-energize, and re-engage the individual/family and employer populations. It's imperative that we have the information on product and rate approvals prior to the 1lth hour and for carriers to compensate brokers appropriately throughout the entire enrollment season.
I am excited to be named to the PHIEA Advisory Council and look forward to being your voice for offering suggestions for the good of our industry, as well as the good of Pennsylvania residents.