Final Rules Issued on Employer-Sponsored Indemnity Insurance

April 18, 2024

Prefer to listen instead of read? No problem! Listen to the blog post at any time by clicking here.   On March 28, 2024, the Departments of Health and Human Services (HHS), Labor, and the Treasury (collectively, the Departments) released final rules governing employer-sponsored indemnity insurance. This type of medical coverage is designed to provide limited-scope benefits and is therefore exempt from certain legal requirements that otherwise apply to major medical plans. As such, indemnity insurance is strictly regulated to ensure that consumers and employees understand what they are buying when they enroll in these plans. Many employers offer hospital or other fixed indemnity insurance products designed to qualify as “excepted benefits,” meaning that they do not have to comply with the Affordable Care Act’s coverage mandates. Under these arrangements, the insurance policy must pay a fixed dollar amount per day (or per other time period) for a hospitalization or illness, regardless of the amount of expenses incurred.  These plans are traditionally used as a form of income replacement upon the occurrence of a health-related event. They are not, nor have they ever been, a substitute for comprehensive coverage. Consumers have the option of using the fixed cash benefit as they wish, whether it be to cover out-of-pocket expenses not covered by comprehensive coverage, or to defray non-medical expenses such as rent or mortgage.  Notably, the guidance emphasizes that employer-sponsored indemnity plans are not permitted to reimburse participants on a per service basis, such as per doctor visit or surgical procedure. Thus, indemnity plans cannot provide benefits in varying amounts based on the type of procedure or item, such as the type of surgery being performed, or the type of prescription drug provided.  In proposed regulations issued last year, the Departments expressed concern regarding employers that offer these plans alongside medical plans that provide minimum essential coverage, but not minimum value (e.g., preventive-care only plans), and suggested prohibiting such arrangements. Specifically, the Departments were concerned that these arrangements are intended to circumvent the Federal consumer protections and requirements for comprehensive coverage that otherwise apply to employer-sponsored plans. Though the proposed prohibition was not adopted in the final rule, the Departments have indicated that they will continue to study the issue, noting that “[n]o inference should be drawn from the decision not to finalize the proposed . . . example[s].”  The Departments did finalize requirements relating to strict new notices that must be provided to employees who are offered indemnity insurance. These notices point out the differences between fixed indemnity excepted benefits coverage and comprehensive coverage. For plan years beginning on or after January 1, 2025, any employer offering hospital indemnity or other fixed indemnity coverage will need to include the notice below in at least 14-point font on the first page (in either paper or electronic form, including on a website) of any marketing, application, and enrollment materials that are provided to participants.   Please feel free to reach out to MZQ Consulting with any questions.

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HHS Delivers Reports to Congress on HIPAA Compliance 

April 11, 2024

Prefer to listen instead of read? No problem! Listen to the blog post at any time by clicking here.    On February 14th, 2024, the Department of Health & Human Services’ (HHS) Office for Civil Rights (OCR) issued two reports regarding Health Insurance Portability and Accountability Act of 1996 (HIPAA)…

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The Integrity Check: A Leader’s Guide to Authenticity

April 4, 2024

It’s all too easy to articulate a vision of the ideal company culture—emphasizing values like work-life balance, respect, and open communication. However, as many of us find out, the real challenge lies not in defining these values but in living them, especially when the pressure mounts. Whether it’s sending emails late into the night or working through weekends, these moments test our commitment to the very culture we advocate for. Ironically, in our bid to lead by example, we might set a standard that contradicts our preached values. This dissonance affects personal wellbeing and can erode trust within your team as they struggle to reconcile what you promote with the behaviors you exhibit. It’s a reminder that leadership is as much about introspection and self-regulation as it is about guiding others. To help maintain alignment between your actions and your stated values, consider this monthly reflection exercise. It can be a personal audit, ensuring you stay true to your vision and lead with integrity.

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Navigating the Future: Advancements in Employee Wellness Programs

March 28, 2024

Prefer to listen instead of read? No problem! Listen to the blog post at any time by clicking here.   Employee wellness is not what it used to be, and that’s a good thing. Gone are the days of traditional approaches like gym memberships and nutrition workshops. Today’s workplace wellness programs are as diverse as the workforce itself, spanning the spectrum from physical to emotional and social wellbeing. Many employees, especially those who are now hybrid or online, see wellness programs as a way for organizations to listen to their needs as individuals. They now include aspects of mental and emotional wellbeing, social interaction, and financial health, reflecting an understanding that wellbeing is complex. With a focus on individual cultures and personal needs, these programs cater to employees’ unique work-life balance requirements.

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Mastering the Juggle: Personal and Professional Work-Life Strategies for Busy Leaders

March 21, 2024

Prefer to listen instead of read? No problem! Listen to the blog post at any time by clicking here.   As a leader or business owner, you may find yourself wondering how you’ll juggle it all in your work and personal life. You know you need to focus on both, but it may be tough to know where to begin.   It doesn’t have to be an either/or situation; you can choose both.

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Webinar: I’m a Health Plan Fiduciary . . . Now What?

March 14, 2024

  Join Q4intelligence and Marissa Rufo of MZQ Consulting for a compliance webinar. When: Wednesday, March 20th, 2024, 11:00 AM Pacific / 2:00 PM Eastern Where: Zoom | Register here   I’m a Health Plan Fiduciary . . . Now What? Learn how to answer that question so you don’t…

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