The following post comes from Gary Skeen, president of CBF’s Church Benefits Board, as part of a blog series related to health care changes due to the Affordable Care Act. Read part 1, part 2, part 3, part 4 and part 5.
The government shut down, but the world didn’t end when the Affordable Care Act came online October 1. A few people are frustrated at the fact that they have not been able to connect to the marketplace exchange online, but those delays were to be expected. There have been several testimonies of folks who appear to be saving money and obtaining healthcare. While the announced delay of the small employer online access to November 1 is disappointing, paper applications are available for those that need immediate help.
We are beginning to get a look at premium rates and policy selection through the exchange marketplace. While it is very difficult to make generalizations, a quick look at the rates indicate they are not very different from what we have observed in the open market.
It is very difficult to generalize because the rates vary by state, county, age, coverage level (bronze, silver, gold, platinum) and plan. There is a significant difference by geographical area, but that is not new.
Remember, these are rates generated by the insurance companies and offered through the exchange; they are not rates determined by the government. The rates are based upon the insurance company’s best understanding of the medical cost, population factors and experience in your area.
Generally the state exchanges have performed better in term of electronic access than the federal exchange, as their volume was a little more predictable and easier to manage. Toward the end of the week, the federal exchange began to handle the volume better, and with continuous updates should begin to run smoothly.
For churches, the delay of the small employer (SHOP) exchange to Nov. 1 is going to make the conversation time-frame tight. To have coverage in place for January 1, you will need to have selected coverage by December 14. This is also important if waiving the 70% participation requirements meets the need of your church group (waived from Nov. 15 to Dec. 15).
Waiting for the SHOP to come online will give you the ability to explore other options available. Take the time to receive quotes from private insurance carriers outside the marketplace for individuals and possibly as a group. You will need these to make an honest comparison to what is available in the exchange.
Have your staff create an account on the exchange and let them explore all the plans available through the marketplace. Remember, you are allowed to window shop; there is no commitment just by creating an account.
When looking at the options available, it is important to know the difference between co-payments and coinsurance, and how they are applied to your medical needs. Don’t assume all bronze level plans are the cheapest and all the platinum level plans offer the best coverage. Your medical needs should dictate the type of coverage you purchase, so take the time to compare all the plans based on your medical history.
We know that health insurance can be frustrating. It is why so many people rely on their employer to give them their option, and when the onus is on them, they frequently go with the cheapest plan available.
But as a church and staff, we must be good stewards of the funds provided to us and we must also provide coverage that adequately insures the health of our staff. The health of the staff and congregation is important in the ability of a church to continue in its mission within its community.
My job at Church Benefits Board is to keep you the church leader informed about what’s coming and help you to navigate the process. Your benefits are our ministry. If I can ever be of assistance, I or a CBB staff member is ready to help. Call us at 1-800-352-8741.
Do Churches that do not have their own 501C3 (fall under a denominational umbrella) have to be added (their FTE’s) to that denominational umbrella for the employer mandate or is each Church considered it’s own ’employer’? I.E. A small Church that only has 3 employees but does not have it’s own 501C3 (under the denominational umbrella) considered a large employer because if you added all the ‘umbrella’ Churches they would equal much more than 50 employees? If not, where does ACA state this, or does it?
Jean, The ACA is really silent on this issue, and in fact it is clear from our communications with HHS that there is a lot about how churches operate that they have not considered. However, I do not think in congregationally based churches where hiring and other employment decisions are made at the local level there will be an issue about being considered aggregate employer. There is plenty of case law to support congregationally based churches being independent employers. However, for those churches with preschools, daycare, and other related ministries it is pretty clear that they will be combined as a single employer unless there is significant evidence of unrelated and separate operations.
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