Download What Is a 21 st Century Intelligent Health System?

Consumerism
and
Actuarial Science
in
A 21st Century Intelligent Health System
Ronald E. Bachman FSA. MAAA
President & CEO
Healthcare Visions, Inc.
404-697-7376
[email protected]
www.healthcarevisions.net
Healthcare Visions, Inc.
Creating the Possible…
Sr. Fellow - Center for Health Transformation
Sr. Fellow - Georgia Public Policy Foundation
Fellow - Wye River Group on Health
What Is a 21st Century Intelligent Health
System?
•
In a 21st Century Intelligent Health System, the individual has:
– Accurate, timely knowledge of personal health needs,
– Access to the best information about how to maintain personal
health,
– Knowledge of whom to see and where to go for health services,
– And confidence that health providers are practicing medicine using
best practices based on the most up-to-date understanding of
outcomes-based medicine.
•
In a 21st Century Intelligent Health System, the individual has the right to know
the price and quality information about health services in the most accurate,
least expensive, and most convenient manner possible.
•
In a 21st Century Intelligent Health System, the individual is the center of
knowledge and decision-making and has responsibility for his or her own
health.
Consumer-directed or Consumerism?
Consumer-directed health plans
(CDHPs) utilizing an HRA or
HSA are the newest weapon in
the arsenal to reduce
healthcare cost.
But will this approach really lower
your cost?
CDHPs are a good start and can
developing experience shows
they can lower costs.
CDHPs are a good 1st generation
attempt. The market is moving
rapidly to 2nd generation and
beyond.
The transformation is NOT to
CDHP but to Consumerism.
Actuaries must go beyond
traditional models to reflect the
behavioral change component
of a consumerism design.
Healthcare Consumerism
Healthcare Consumerism is about transforming a health
benefit plan into one that puts economic purchasing
power—and decision-making—in the hands of
participants.
It’s about supplying the information and decision support
tools they need, along with financial incentives,
rewards, and other benefits that encourage personal
involvement in altering health and healthcare
purchasing behaviors.
Elements of Healthcare Consumerism
1. Budgeting
– monthly versus annual
2. Risk Sharing – pooled claims for large
groups
3. Savings – NEW with advent of HRAs and
HSAs
The Core of Consumerism
The Unifying Theme
for a
Health and Healthcare Strategy is:
Behavioral Change
“Implement only if it supports
behavioral change consistent with the
strategy”
Two Basic Principles for
Successful Consumerism
1. Must work for the Sickest Members,
as well as the healthy
2. Must work for those not wanting to
get involved in decision-making, as
well as the “techies”
Mega Trends
1.Personal Responsibility
2.Self-Help, Self-Care
3.Individual Ownership
4.Portability
5.Transparency (the Right to Know)
6.Consumerism (Empowerment)
The Evolution
of Healthcare and Consumerism
Future Generations of Consumer Directed Healthcare
Traditional
Plans
Traditional
Plans
with
Consumer
Information
1st Generation 2nd Generation 3rd Generation
CDHC
CDHC
CDHC
Focus on
Discretionary
Spending
Focus on
Behavior
Changes
4th Generation
CDHC
Integrated
Health &
Performance
Behavioral Change and Cost Management Potential
Low Impact
---- ---- ---- ---- ---- ---- ---- ---- ----
High Impact
Personalized
Health &
Healthcare
Major Building Blocks of Consumerism
•
Personal Accounts
Wellness/Prevention
Early Intervention
Disease Management
Information
Decision Support
Incentives &
Rewards
It is the creative
development, efficient
delivery, efficacy, and
successful integration of
these elements that will
prove the success or failure
of consumerism.
Summary –
A peek into the
future of
Consumerism
Personal Accounts
Wellness/Prevention
Early Intervention
Disease Management
Information
Decision Support
Incentives &
Rewards
1st Generation
CDHC
Focus on
Discretionary
Spending
Initial
Account Only
2nd Generation
CDHC
3rd Generation
CDHC
Focus on
Behavior
Changes
Integrated
Health &
Performance
Activity &
Compliance
Rewards
Web-based behavior
100% Basic
change support
Preventive Care
programs
4th Generation
CDHC
Personalized
Health &
Healthcare
Indiv. & Group
Corporate Metric
Rewards
Specialized Accts,
Matching HRAs,
Expanded QME
Worksite wellness,
safety, stress & error
reduction
Genomics, predictive
modeling push
technology
Information,
health coach
Compliance Awards, Population Mgmt, IHM, Wireless cyber –
disease specific Integrated Back-to-Work support, cultural DM,
allowances
Holistic care
Passive Info
Discretionary
Expenses
Personal health
Health & performance
mgmt, info with
info, integrated health
incentives to access
work data
Cash, tickets,
Trinkets
Zero balance acct, Non-health corporate Personal development
activity based
metric driven incentives plan incentives, health
incentives
status related
Arrive in time info
and services,
information therapy
Using Information & Incentives
To Change Behaviors
Low Users
No
Claims
Medium
Users
Generally
Healthy
Acute Episodic Conditions
O/P, Low
% Mem
% Dollars
15%
48%
14%
3%
3%
Wellness - Lifestyle
Prevention
0%
In/P, High Maternity
12%
15%
12%
63%
Chronic & Persistent
.
Conditions
.
O/P, Low In/P, High
Catastrophic
12%
4%
1%
21%
20%
15%
Minimize
32%
17%
Maximize
% Dollars
Very High
Users
Wellness - Lifestyle
5%
Minimize
% Mem
High
Users
12%
32%
Early Intervention
Wellness - Clinical
Maximize 56%
Wellness - Clinical
Personal Health Management
Decision Support & Information
% Ee
%
Dollars
% Ee
%
Dollars
Low Users
Medium Users
Genera
No
lly
Claim
Health
s
y
Acute Episodic
Conditions
O/P,
Low
In/P,
High
Reduce Variation in
Evidence-Based
Medicine
Discretionary
Expenses
Mater
nity
Pre-Natal
Care
High Users
Very High
Users
Chronic &
Persistent
Conditions
O/P,
In/P,
Low High
Catastrop
hic
Reduce Variation in
Evidence-Based
Medicine
Patient
Safety
Disease
Management
Centers of
Excellence
Psycho-Social Factors / Integrated Absence Management
Patient
Advocacy/
Case
Management
Care Continuum and
Tools for Changing Behaviors
Well
At Risk
e.g., Low Risk, Good
Nutrition, Active
Lifestyle
e.g., Inactivity, High
Stress, Overweight,
High Blood Pressure
Chronic
Conditions
Catastrophic
Conditions
e.g., Depression,
Heart Disease
e.g., Cancer,
Hepatitis C
Acute Conditions
e.g., Infections, Respiratory, Lacerations
Health
Promotion
Health Risk
Management
Chronic Disease
Management
High Cost Case
Management
Website
Health Risk
Assessment
Patient Identification
and enrollment
Navigational Support
HealthyLifestyle
Promotion
Targeted Behavior
Modification
Address Comorbid
Conditions
Patient Advocacy
Physical Activity
Campaign
Practice Guidelines
Care Coordination
Integrated Services, Communications, Measurement and Evaluation
Care Coordination
Address Comorbid
Conditions
Integrated Health Management Program
An Implementation Option for Multiple Generations
General Manager
Personal Care Accts.
FSAs, HRAs, HSAs
Integrated Absence Mgmt
Acute Case Mgmt
Disease Mgmt Programs
Demand Management
The secret is
cooperation and
synergy between
components supporting
the corporate strategies
Prevention
Wellness
Communication
Education
Utilization and Case Management
NETWORK A / TPA A
NETWORK B / TPA B
Potential Savings from
Full Implementation of Consumerism
Achievement of savings and improved outcomes is dependent upon both
the Type and Effectiveness of the programs implemented.
Gross* Savings as % of Total Plan Costs
(Programs Applicable to All Members)
Traditional plans
Effective
Programs
Implemented
Consumerism Plans
Passive
1st Generation
2nd Generation
3rd Gen & Future
Basic
2%
3%
7%
10%
Expanded
3-4%
5-8%
12-15.0%
20.0+%
Complete
4%
7%
17%
25%
5%
10%
20%
30%
Comprehensive
(Future)
*Excludes Carry-over HRAs/HSAs and any added
Administrative Costs of Specialized Programs
Major Actuarial Issues
•
•
•
•
Anti-selection,
Value of wellness,
Disease management ROI,
Actuarial credits for behavioral change
Understanding Risk
Selection and Anti-selection
The primary drivers of risk selection are
employee cost and the relative benefit
richness of the competing options.
Employees will tend to choose the option
expected to provide the best economic
benefit for their situation.
For healthy individuals the selection is
usually low cost/low benefit options.
For less healthy individuals the selection
is usually high cost/high benefit options.
Higher Cost
e.g., Not typically
seen
e.g., PPO
or POS
Moderate
Adverse
Selection
High
Adverse
Selection
High
Benefit
Low
Benefit
High
Positive
Selection
Moderate
Positive
Selection
e.g., Age
-Rated
HMO
e.g., Core
Plan
Lower Cost
Selection effect is at least directionally predictable in most cases.
Mitigating factors tend to reduce the magnitude of selection.
Health care costs are not fully predictable.
Plan choices are usually made at a family unit level versus the individual level.
.
Potential Anti-Selection
from CDHC on an Optional Basis
•
Introduction of CDHC on an optional basis will limit the cost
reduction because fewer members will be impacted and because
the members that do select CDHC are likely to have an existing
favorable health status (anti-selection). Adopting companies and
its members can benefit most by introducing consumerism with
both a CDHC option and consumerism for all other plans.
Example - Selection in An Option Environment
OPTION # 1 – Current Plan
OPTION # 2 - CDHC
% Members
Participating
Clms/Part.Mbr. Vs
Clms/All Mbrs.
Remaining
Members
Clms/Part.Mbr. Vs
Clms/All Mbrs.
90%
101%
10%
87%
70%
103%
30%
92%
50%
103%
50%
97%
Consumerism Choices involve
Options for Behavioral Change rather than
Optional Plan Designs
• Consumerism Choices:
•
•
•
•
•
•
•
•
•
Wellness
Preventive care
Early Intervention
Lifestyle Options (diet, exercise, smoking, safety)
Self-help, self care
Discretionary Expenses (e.g. OV, ER, Rx)
Value purchasing (e.g. DXL, o/p vs. in/p)
Participation in Disease Management Programs
Compliance with Evidence Based Medicine Treatment Plans
Survey Results
Wellness Assessment Risk Factors
Risk Factors for Health Conditions
30%
Overdue Preventive Visits
Alcohol Use
1%
Tobacco Use
8%
Poor Diet
81%
60%
Physical Inactivity
Overweight/Underweight
77%
Stress
27%
0%
10%
20%
30%
40%
50%
60%
70%
80%
90%
Value of Wellness – What is it?
How Much Physical Activity Do the Experts Recommend? 30? 60? 90?
Minutes of What?
The Centers for Disease Control and Prevention and the American
College of Sports Medicine recommend the following:
•
20 minutes of vigorous-intensity physical activity 3 times a
week or
•
30 minutes of moderate-intensity physical activity 5 or more
times a week.
What is moderate-intensity physical activity? Any activity that burns 3.5
to 7 calories per minute (e.g., walking briskly).
What is vigorous-intensity physical activity? Any activity that burns 7 or
more calories per minute (e.g.,
climbing up and down stairs).
National Business Group on Health
Comments on Wellness
Recent studies indicate that moderate increases in employees’ physical
activity levels can result in significant decreases in company costs.
Although existing research is limited, employers may use calculation
tools and internal data to calculate the potential savings of an
effective physical activity promotion program.
To reach a rough estimate of the cost of its employees’ physical
inactivity, a company could turn to www.activelivingleadership.org for
a new online tool.
This Physical Inactivity Cost Calculator was developed by, among
others, the Active Living Leadership Initiative, Fifty Plus Lifelong
Fitness and the National Coalition for Promoting Physical Activity
and Health.
Examples of Corporate Wellness & ROI
Motorola’s wellness programs which saves the company
$3.93 for every $1 invested.
Northeast Utilities WellAware Program which in its first 24
months reduced lifestyle and behavioral claims by
$1,400,000.
Caterpillar’s Healthy Balance program which is projected to
result in long term savings of $700 million by 2015.
Johnson & Johnson’s Health and Wellness Program which has
produced average annual health care savings of $224.66 per
employee.
Wellness ROI Studies
Many studies have focused specifically on the return on investment
(ROI) from worksite health promotion and disease prevention
programs.
Findings on the return on investment for health promotion and disease
management programs were reported for nine employers: Canada &
North America Life; Chevron.; City of Mesa, AZ; General Mills;
General Motors; Johnson & Johnson; Pacific Bell; Procter &
Gamble; and Tenneco. These programs provide health education to
their employees to promote behaviors that will improve health or
prevent disease, and typically include exercise programs, health-risk
appraisal, weight control, nutrition information, stress management,
disease screening, and smoking cessation.
The review found significant return on investment for the programs
provided by these nine employers, with the range of benefit-to-cost
ratios, ranging from $1.49 to $4.91 in benefits per dollar spent on the
program, and a median of $3.14.
Savings from National Wellness Program
Savings estimates revealed that participation in the National Wellness
Program was associated with significant savings in dollars per
employee from 1991 to 1995, with the highest dollar savings
achieved in 1995 ($16 per employee per month).
Evaluation of the program showed that health risk assessment was
associated with significant and substantial reductions in healthcare
costs.
Employees who completed one, two, or three health risk assessments
on average had lower 1997 health care costs of $112.89, $134.22,
and $152.29, respectively. Employees who had completed at least
one health risk assessment and participated in an additional
wellness activity had an average cost savings of $200.35 per year.
CIGNA Wellness Savings
The Working Well Moms Program has decreased pharmacy costs –
62% fewer prescriptions for breast-fed children. The program has
also contributed to decreased medical costs – a savings of $240,000
in healthcare expenses. In addition, program participants have 74
fewer absences per 100 mothers, a savings of $60,000 in lost time
annually.
The Working Well Triumph Program has resulted in healthcare costs
savings of more than $900 per program participant.
The Working Well Flu Shots Program participants have 29% less
absenteeism as compared to employees not getting a shot. This
produced a savings of $33 per employee participant. The overall
return on investment for the program was 3 to 1.
CIGNA’s smoking cessation program helped 67 percent of its
participants quit smoking after 12 months, a quit rate up to three
times higher than comparable smoking cessation programs. CIGNA
estimates saving $949 in health care costs for each successful
participant, a return on investment of 9.5 to 1.
Disease Management for
Chronic and Persistent Conditions
The Agriculture and Health and Human Services Departments’ Dietary
Guidelines for Americans 2005 recommend the following:
•
To reduce the risk of chronic disease—at least 30 minutes of
moderate-intensity physical activity on most, preferably all days of
the week;
•
To prevent the gradual accumulation of excess weight in
adulthood, up to 30 additional minutes per day may be required over
the 30 minutes for reduction of chronic disease risk and other health
benefits; and
•
To sustain weight loss for previously overweight/obese people,
about 60 to 90 minutes of moderate-intensity physical activity per
day is recommended.
Disease Management Program ROI
Program Type:
DM vendor pricing
method
Percentage of chronic
diseased
participating in
program
Return on investment
of disease
management
programs
Passive
Phone and mail
out- reach, no
incentives
Assertive
Incentives (i.e.,
waiving Rx copays)
Aggressive
Incentives (i.e,
waiving Rx copays,
premium
differential
Per employee
per month, all
employees
Low PEPM on all ees
plus hourly or per
case rate on
participants only (rate
varies based on
participant risk
status)
Low PEPM on all
ees plus hourly or
per case rate on
participants only
(rate varies based
on participant risk
status)
10%
50%
75%
0 - .5
1.5 - 2
1.5 - 3
First Year Aetna HealthFund Members
2004 results (9 mos.) show low medical cost increase
Continuously Enrolled Members: Allowed claims
Medical Claims
% Change
2003 Study
(13.5K members)
3.7% increase in medical cost
2004 Study
(9 mos.)
(49K members)
Early indicators 6% increase in
medical cost over 2003
Change in Utilization
(# of Units)
2003 Study
2004 Study
(12 months of data)
(9 months of data)
Inpatient Admissions
-5.2%
-6.7%
ER Visits
-2.6%
-15.9%
Outpatient Events
-14.4%
-4.6%
ALL Office Visits
-3.3%
-3.4%
PCP Visits
-10.9%
-12.3%
Specialists visits
+3.4%
+3.6%
Note: 12 month continuously enrolled results due in August
What Happens in the Second Year to Allowed Claims?
Allowed Claims PMPM
$260
+10.3%
PPO
$240
$220
AHF**
$200
$180
+8.7%
$160
$140
1Q ’03
2Q ’03
3Q ’03
4Q ’03
1Q ’04
2Q ‘04
3Q ’04
4Q ’04
• Utilization in AHF increased at a lower rate than PPO, based on allowed* claims
• Reinforces assumption that AHF trend will be 1% below PPO
• Studies will continue to evaluate AHF trend into the third year
* Allowed Claims are total claims, eligible for payment before benefit plan is applied
** Based on all AHF members from 18 of 19 plan sponsors in 2003 study; one plan sponsor removed due to large increase in AHF enrollment.
Highlights of the 2003 Aetna
HealthFund 12-Month Study
• Lower medical cost increase, applicable to first-year AHF
members - 3.7 % compared to double digit PPO plans
• Diabetics continue to seek necessary care, relative to
comparative populations
• Increases in certain preventive care services
• Reduction in pharmacy scripts and increased generic
usage
• Increased use of online tools, information, and satisfied
members
2004 United Health Plan Experience
The iPlan study found:
• A drop in the number of claims per 1,000 enrollees compared to the
year before enrollment;
• A decrease in total emergency room visits, illustrating more
selective, responsible use of emergency services;
• Significantly less-than-expected medical cost trends (per
member/per month) than for traditional health plans; when iPlan was
the only option, the annual cost trend was less than 1 percent;
• Reductions in specialist visits, outpatient surgeries and radiology
and lab services; and
• Higher utilization of preventive services among iPlan participants.
Lumenos
Key Results – Utilization Impact
• 15% reduction in pharmacy costs
• 92% generic substitution rate (open formulary, 100% of
rebates go back to employer)
• 5% increase in preventive care expenditures
• 18% reduction in outpatient visits
• 85% graduation rate (Health Coach Program)
• 42% HRA completion with incentive; 28% opt-in to Health
Coach
• 60% of clients offer integrated health improvement incentives.
Are HSAs the right vehicle for large
employer groups?
Yes, If………..
Or
No, Because…….
Need to Understand the Consumer
Movement & the Transformation
that is Underway
HSAs and HRAs Very Different
HSA – A law, with specific requirements and benefit design
requirements.
Most TAX ADVANTAGED vehicle ever created
*******************************************************
HRAs – No Law, this is a regulatory creation based upon
an IRS ruling.
Most FLEXIBLE vehicle ever created
Incentive Awards - Three Very Different
Personal Care Accounts
• FSAs – Traditional Group Plans
• Health Reimbursements Arrangements (HRAs) – Employers’
choice for cash flow flexible incentive based medical plan
benefit designs (best suited for self-insured groups)
• Health Savings Accounts (HSAs) – Employees’ choice for
funded portable triple tax advantaged with “High Deductible
Health Plans” (best suited for individuals and small groups)
• Combination Accounts – creative but confusing
Important Differences between Use of
HRAs and HSAs for Supporting
Behavioral Change
Personal
Care
Accounts
Health
Reimbursement
Arrangements
Health Savings
Accounts
Generation 1
Initial
Account Only
Generation 2
Generation 3
Activity & Compliance Indiv. & Group Corporate
Rewards
Metric Rewards
Generation 4
Specialized Accts,
Matching HRAs,
Expanded QME
1. Any Amount
2. Notional Acct
3. Employer
Determined
4. Employer Only
Contributions
1. Flexible Activity &
Compliance Rewards
2. Employer Determined
3. Can not be cashed out
4. Must be used for
healthcare
1. Flexible Indiv & Group
Rewards
2. Employer Determined
3. Can not be cashed out
4. Must be used for healthcare
1. Specialized Notional
Accts,
2. Can terminate by
employer rules
3. Potential IRS Expanded
QME
1. Amounts Set by law
2. Real Dollars in Acct
3. Er or Ee Contrib
4. Contributions up to
plan deductible of
$1000-2650 Single
$2000-5250 Family
1. Ltd Potential
2. Must give Cash Option
3. Awards must be same
$ amt or same % of
deductible
3. HSA can be used (with
10% penalty) for nonhealthcare expenses
1. Ltd Potential
2. All participants must
receive same amount or
same % of deductible
3. Difficult to use for Group
Incentives
1. Ltd Potential
2. 100% Vested &
Portable
3. Can use matching
HRAs,
4. Potential IRS
Expanded QME
The Evolution of Personal Care Accounts
•
Combination
Accounts
Employerbased
healthcare
Special
Purpose
Accounts
Incentive
Matching
Current State
HRAs
Employerbased
Healthcare
with Individual
Accountability
HSAs
Individual-based
Healthcare
FSAs
Employer-based
Healthcare
Employer-based
Traditional (Use
it or Lose it)
Defined Contribution
Developments
Special Purpose
Non-Plan
Are HSAs the Wave of the Future?
Which Point of View Direction will We Take?
Yes, if….
1. we recognize the HSA legislation and regulations as a good start and another
building block for consumerism and behavioral change.
2. there is additional legislation/regulation to support large Er interests in providing
HSAs (use for healthcare only, Rx coverage problem, combination accounts).
3. there is legislative support for the common use of FSAs for targeted needs, HSAs
as “Health Savings Accounts” and HRAs as “Health Reimbursement
Arrangements.
No, because….
1. they were not legislated/regulated with large employers in mind.
2. of a desire to promote individual insurance over individual ownership (under
employer and individual policies)
3. they are just a tool to cost shift to employees, they can not reward behavior
change
4. they are only desirable to the young, healthy, and wealthy
Are HSAs the right vehicle for large
employer groups?
Yes, If………..
Or
No, Because…….
Need to Understand the Consumer
Movement & the Transformation
that is Underway
The Fundamental Policy Question
Will Legislation/Regulation Use HSAs to:
… mainly promote portable Individual & Small
Group Insurance,
OR
… expand Personal Care Account ownership
through in both an employer-based and
individual-based healthcare system thru
HSAs, HRAs, and FSAs.
Growth of Personal Care Accounts
2000*
2001*
2002*
2003*
2004(est)
2005(est)
2006(est)
2007(est)
HRAs
None
19,000
53,000
394,000
1-1.5M
3.2 M
6.0+M
12-15M
* Deliotte Consulting
HSAs
None
None
None
None
400,000
1.0M+
???
???
The Answer –
Flexible Health Savings Accounts (FHSAs)
FHSAs would have the tax advantages of HSAs and the
key flexibilities of HRAs.
Basic Principles:
1. Retain personal responsibility goal of HSA/HDHPs
2. Focus on Behavior Change
3. Recognize value of Pay for Compliance as a driver for
behavior change and shared savings with personal
responsibility
4. Expand adoption and funding of HSAs by large
employers
Flexible Health Savings Accounts (FHSAs)
The Next Generation
Four needs that would allow FHSAs the flexibility to:
1. Provide financial Rewards and Incentives for Behavioral
Change.
2. Encourage Employer/Carrier FHSA contributions
towards healthcare
3. Be provided with plan designs other than HDHPs
4. Address FHSA/HSA Technical Issues
FHSA Flexibilty to Provide Financial
Rewards and Incentives for Behavioral
Change
1. Allow for compliance incentives under disease
management programs (e.g. diabetes, asthma, CHF)
and wellness initiatives (e.g. wellness assessments,
smoking cessation, etc.).
2. Change Comparability Rule to mean all members under
a given program of care or treatment, such as, a
disease management or wellness program.
3. Rewards and/or incentives should not be limited by the
deductible limit, but should be consistent with expected
savings from programs for which participation is being
rewarded.
FHSA Flexibility to Encourage
Employer Contributions to Healthcare
1. Allow employers/carriers to voluntarily contract with
employees to require employer/carrier funded FHSAs
to be used only for healthcare expenses while
employed and covered under the plan.
2. Remove cap on employer/carrier funded FHSA
contributions or expand to at least the plan’s
Maximum Out-Of-Pocket total exposure in a given
calendar year.
FHSAs Flexibility to be Provided with
Plan Designs Other than HDHPs
1. Preventive drugs include maintenance drugs. Drugs now
defined as preventive by the Treasury Dept. can be covered
below the deductible, while the cost of maintenance drugs is
now included in the deductible.
2. Allow Rx to exist as carve out benefits at least for
prescription drugs associated with chronic and persistent
disease states
3. Allow “incentive only based” FHSAs for employer/carrier only
funding under non-HDHPs (i.e. no initial FHSA funding or
employee funding)
4. Allow some mental health and substance abuse benefits
(besides EAPs) to be included under preventive care.
FHSA Flexibility - Technical Issues
1. Allow FHSA/HSAs to go into effect on the first day of
coverage is effective.
2. Allow FHSA/HSA contributions for a full calendar year
regardless of when a plan is effective.
3. Allow FHSA/HSAs to be used to pay for health coverage
premiums (other than current limited use for (1) Premiums for
coverage under the Consolidated Omnibus Budget
Reconciliation Act (COBRA), and (2) premiums for HDHP
coverage for those who receive federal or state
unemployment compensation).
4. Allow Flexibility to "post-date" the FHSA/HSA effective date
so that FHSA/HSA dollars can cover expenses incurred
before the account was established. Allow the account to be
opened under a "provisional status" until the necessary
paperwork is filed, at which time the account becomes active.
The Ultimate Successful
Implementation of Consumerism
It’s about moving from a
“benefit”
to an
“accumulating asset.”