The Pension Boards administers a comprehensive set of Retirement and Health and Welfare Benefits on behalf of active and retired clergy and lay employees and their dependents, that must conform to and comply with various State and Federal laws.
With the passage of the Patient Protection and Affordable Care Act of 2010 (PPACA) in March, 2010, Congress enacted the most far-reaching changes in the history of health benefit plans. The over 2,600 pages of the initial bill were quickly followed by the additional rules within the Health Care and Education Tax Credits Reconciliation Act of 2010.
President Obama said that Americans can “keep the coverage they have” under the health care reform law. To carry out that promise, the health care reform legislation “grandfathers” certain existing group health plans. Grandfathered plans are subject to some, but not all, of the requirements of the health care legislation. A group health plan is grandfathered under the legislation if the plan was providing coverage to any individual on March 23, 2010, the date of enactment of the legislation. Since the UCC Medical Benefits Plan meets that criterion, it is a grandfathered group health plan under the legislation.
Being a grandfathered plan has the advantage of being able to continue to provide access to the doctors, medical service providers and pharmacy benefits as we have them today. As a grandfathered plan, the UCC Medical Benefits Plan is required to comply with certain coverage and benefit requirements, but these will have less of an impact on premiums than some of the administrative and reporting requirements applicable to other group health plans.
The following health care reform legislative provisions are applicable to grandfathered plans and to the UCC Medical Benefits Plan:
A. No lifetime or annual limits on benefits
We are pleased to note that the UCC Medical Benefits Plan does not have any lifetime limit on benefit payments and already meets a part of this requirement. The Plan does have an annual renewable benefit limit of $2,000,000, for plan year 2013, which complies with federal guidelines.
B. Extension of dependent coverage to age 26
Until PPACA, the UCC Medical Benefits Plan covered dependent children to age 19 or to age 25 for continuing unmarried students. The Pension Boards announced that, effective July 1, 2010, the UCC Medical Benefits Plan will extend coverage to adult children of participants until the child attains age 26 and will remove the “student status” and “unmarried” criteria as required by the new legislation. As provided in the new legislation, until 2014, an adult child under age 26 who is eligible to enroll in another employer-sponsored group health plan will not be eligible for adult child coverage under the UCC Medical Benefits Plan. The Pension Boards has provided participants with information about enrolling their adult children in the Plan.
C. No rescissions or cancellations of coverage based on claims
We are pleased to note that the UCC Medical Benefits Plan has never cancelled any participant’s coverage due to the number of claims or the amount of dollars paid as benefits. This portion of the new legislation will have no effect on our Plan’s administration.
D. A plan may not impose any pre-existing condition exclusions
The new legislation does not allow a group health plan to enroll a participant and then exclude or limit benefit payments for pre-existing conditions. We are pleased to note that the UCC Medical Benefits Plan does not have this practice in place and this requirement will have no effect on our Plan’s administration.
E. No waiting period greater than 90 days
Effective January 1, 2014, employers may not impose a waiting period that exceeds 90 days. The present design of the UCC Medical Benefits Plan does not mandate any specific waiting period, but gives local churches and ministries the option of setting their own waiting period. On the effective date of this change, local churches and ministries will need to conform to the waiting period limitation.
Going forward, the Department of Health and Human Services is the federal agency charged with the establishment of policies and procedures to implement PPACA. Since the enactment of the law, there have been several emerging issues; most notable is the expansion of Women’s Health Care Services.
Preventive health services for women, including coverage for contraceptives, have been part of the UCC health plan for many years. The health plan offers preventive services at 100% coverage, without payment of office co-pays or co-insurance. In addition, several years ago the health plan expanded coverage for maternity services for covered individuals.
There is a copay included for the purchase of prescription contraceptive drugs provided by the health plan. This is consistent with the pharmacy policies of the health plan, as the health plan requires payment of a co-pay for all prescription drugs and medications purchased by participants under the health plan, to help control costs.
The Pension Boards, as the administrator of the UCC health plan, has a long history of supporting and providing for women’s health care rights for its members. The Pension Boards recognizes and respects the right of other denominations with alternate views on coverage of contraceptive services and supports their efforts to receive protection under the law.
For additional information, please contact Frank Loiacono, Director, Health Plan Operations at firstname.lastname@example.org or you may reach a Health Services Representative by calling toll-free at 1.800.642.6543, ext. 2870.