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www.fiducial.com. 2. WELCOME!. In this training session you will learn: The Pros and Cons of HSA's for you and your employeesHow to Avoid Pitfalls and Set up HSA's correctlyHow HSA's relate to other consumer-directed health plansWhat a high-deductible health plan (HDHP) is and why its required
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1. www.fiducial.com HSA’s “Are They Your Ticket To Lower Health Costs”? Presented By: Meredith Lindenmann
2. www.fiducial.com 2 WELCOME! In this training session you will learn:
The Pros and Cons of HSA’s for you and your employees
How to Avoid Pitfalls and Set up HSA’s correctly
How HSA’s relate to other consumer-directed health plans
What a high-deductible health plan (HDHP) is and why its required for an HSA
The rules on HSA contributions, who can contribute, and how much
The rules on HSA distributions and the penalties for non-medical withdrawals
How HSA’s work with cafeteria plans
3. www.fiducial.com 3 ABC’s of Health Options Know Your Acronyms:
CDH:
HSA:
FSA:
HRA:
HDHP:
OTC:
4. www.fiducial.com 4 CDH Defined HRA – Health Reimbursement Account:
allow employees to debit medical expenses and allow for year to year rollover. HRA is not portable nor does it belong to the employee. HRAs are employer-owned, and the account’s interest belongs to the employer.
FSA – Flexible Spending Account:
are IRS Section 125 cafeteria plans that allow employees to have money deducted from their paychecks on a pre-tax basis and placed into an account that can be used to pay insurance premiums and un-reimbursed medical expenses. Employers may also contribute to the account. Funds in an FSA do not roll over at the end of the year; they are forfeited by the employee.
HSA – Health Savings Account:
is a tax sheltered savings account that is dedicated for medical expenses, tied to an HDHP (high-deductible health insurance plan). Funds in the account can be used to pay for medical expenses until the deductible threshold is reached (deductible must be at $1,000 for individuals, $2,000 for family).
5. www.fiducial.com 5 Healthcare Management Tools for managing health care costs
50% to 80% of health care expenditures are related to lifestyle choices:
smoking
not wearing a seatbelt
drinking too much
overeating
choosing bad foods and not exercising
Wellness Programs
Smoking Cessation
Weight Management
HSA = Health Savings Accounts
lead employees to different purchasing behavior
motivate employees to manage their personal health and health costs better
6. www.fiducial.com 6 Promoting Wellness
Employer Sponsored Wellness Programs on the rise:
Exercise and fitness
Smoking cessation
Blood pressure management
Weight management
Stress management
Nutrition
Payoffs of having healthy workers:
Lower health care costs
Higher productivity
Greater labor market competitiveness
7. www.fiducial.com 7 Recipe for Success Have an aggressive strategy to control health care costs
Be decisive and swift in implementing programs
Behave as you would with any out-of-control expense
Use employee feedback and evaluation to learn what is and is not working
Make changes accordingly
Point of care cost-sharing and premiums are a must
When people have a financial reason to pay attention to healthcare costs, they do pay attention
Study fairly recent health care claims and target issues that are your cost drivers
Provide information, education and online tools for employees
Including how they can manage their out-of-pocket costs
8. www.fiducial.com 8 Distinguishing Health Options How do HSA’s compare to other consumer-driven health plans?
Similarities:
HSAs, FSAs, and HRAs all enable users to pay for out-of-pocket health expenses (and some dependent health costs) with pretax dollars
Differences/Benefits of HSA:
Can be funded by employees (as can FSAs but not HRAs)
Require a high-deductible health insurance policy (unlike FSAs and some HRAs)
Allow participants to roll over unused funds from year to year
Allow employees to choose account investments
Are portable when an employee switches jobs
Provide survivor benefits
9. www.fiducial.com 9 Health Savings Account New Annual Contribution Levels for HSA (For 2005)
The maximum annual HSA contribution for an eligible individual with self-only coverage is $2,650.00
For family coverage the maximum annual HSA contribution is $5,250.00
“Catch-up Contributions” for individuals who are 55 or older is increased by statute from $500.00 to $600.00 (increasing $100 per year, up to $1,000 per year in 2009)
Both the HSA contribution and catch up contribution apply pro rata based on the number of months of the year a taxpayer is an eligible individual, and, with respect to the catch up contribution, the number of months of the year that the taxpayer is age 55 and over
New Amounts for Out-of-Pocket Spending on HSA-Compatible HDHPs
The maximum annual out-of-pocket amount for HDHP self-coverage increases to $5,100.00
The maximum annual out-of-pocket amount for HDHP family coverage is twice that, $10,200.00.
Minimum Deductible Amounts for HSA-Compatible HDHPs
The minimum deductible for HDHP is unchanged, at $1,000.00 for self-only coverage
The minimum deductible for family coverage is $2,000.00
10. www.fiducial.com 10 Health Savings Accounts An HSA can benefit anyone who currently pays taxes:
Individual Contributors
Whether or not an individual itemizes deductions, the individual gets a tax deduction for amounts that he or she contributes to an HSA (up to the statutory limit)
Employer contributions and/or employee pre-tax salary reductions through cafeteria plan
Deductible by employer up to statutory limits
Excludable from employee’s taxable income and not subject to federal income tax withholding, FICA or FUTA
Amounts in the HSA build up on a tax-free basis and are portable
Distributions for qualified medical expenses are not taxed
11. www.fiducial.com 11 Health Savings Accounts Additional Rules/Requirements:
Money from an HSA may be spent tax-free on medical expenses both before and after age 65
Withdrawals for non-medical expenses before age 65 will be hit with a 10% penalty plus income taxes on the funds withdrawn
After age 65, money can be withdrawn for non-medical expenses without triggering the 10% penalty, but employees will still have to pay income taxes on the money, thus the HSA turns into a retirement account
Most HSA’s are expected to be provided through employer plans that combine both health insurance and savings accounts
Individuals with their own high-deductible health policies can purchase HSA’s directly from financial services providers
12. www.fiducial.com 12 Benefits of HSA Benefits for Employers:
It is difficult for small businesses to offer insurance to employees
The combination of an HDHP and an HSA lowers the insurance rates for an employer, creating a situation in which small businesses can afford to provide insurance!
Benefits for Employees:
Deposits into the spending account are tax-deductible
Account can be used to pay routine medical bills, including insurance premiums
Any unused amount remains at the end of the year and stays in the account and grows
Helps reduce premium costs
Lowers an employee’s taxable income
Gives employees autonomy and control over their health-care spending
Plans are portable
13. www.fiducial.com 13 Health Savings Accounts HSAs can be offered through a cafeteria plan
May be funded with pre-tax salary reductions, employer flex credits or both
Code 125 nondiscrimination rules do apply
HSA comparability rules do not apply to employer contributions to HSAs that are made through a cafeteria plan (including ones made pursuant to pre-tax salary reductions)
Irrevocable election rules do not apply
HSA elections can be changed prospectively at any time
“Use it or lose it” uniform coverage, and 12-month period of coverage rules do not apply
Employer funding – Pay-as-you-go, in advance, or at year-end
Automatic elections permitted but employee needs to establish account
14. www.fiducial.com 14 HSA’s – Who can have one? “Eligible individuals” can have HSAs
Eligibility and contribution limits determined month by month – no partial months
Eligible individual must:
Be covered by a high-deductible health plan (HDHP) as of the first day of the month
Not be covered by a low or no deductible plan (a non-HDHP) unless it is “preventive care” or “permitted coverage” or “permitted insurance” – the three P’s
Not be entitled to Medicare (entitled = eligible + enrolled)
Not be able to be claimed as a dependent on another persons tax return
15. www.fiducial.com 15 HSAs – High Deductible Health Plans What is an HDHP?
A comprehensive health plan (insured or self-insured) with an annual deductible of at least:
$1,000 for self-only coverage
$2,000 for family coverage
Family coverage is any coverage that is not self-only coverage
Except for preventive care, an HDHP may not provide benefits until the deductible for the year is met
Out of pocket expenses under an HDHP may not exceed specified limits:
$5,100 for self-only coverage
$10,200 for family coverage (2005 limits)
16. www.fiducial.com 16 HSA’s – What other coverage is allowed? The Three Ps (Preventive Care, Permitted Coverage, Permitted Insurance)
What is “Preventive Care”?
IRS Notice 2004-23 describes the preventive care services that an HDHP can offer
Periodic health examinations, immunizations, tobacco cessation and obesity weigh-loss programs and listed screening services
Not services treating an existing illness, injury or condition
Preventive care may include treatment of a related condition
In narrow circumstances, certain drugs or medications may constitute preventive care
IRS definition of preventive care controls over state mandate definitions
17. www.fiducial.com 17 HSAs – What other coverage is allowed? The Three Ps
“Permitted Coverage” is coverage (whether through insurance or otherwise) for:
Accidents
Disability
Dental Care
Vision Care
Long term care
18. www.fiducial.com 18 HSA’s What other coverage is allowed? The Three Ps
“Permitted Insurance”
Insurance if substantially all of its coverage relates to –
Liabilities under workers compensation laws
Tort liabilities
Liabilities relating to ownership or use of property
Other similar liabilities as prescribed in future regulations
Insurance for a specified disease or illness
Example: Cancer insurance
Principal health coverage must be provided through HDHP
Insurance paying a fixed amount per day of hospitalization
19. www.fiducial.com 19 HSA’s What other coverage is allowed? The Three Ps
No “carve-out” coverage allowed
Revenue Ruling 2004-38 confirms that separate low-or no-deductible prescription drug plan will make an individual ineligible for an HSA
Prescription drug plan or rider in which there are no deductibles but rather co-pay amounts would disqualify an otherwise eligible individual from participating in an HSA
Rationale of Revenue Ruling 2004-38 closes the door on other “carve-out” coverage
Prescription Drug Transition Relief (Revenue Procedure 2004-22)
IRS allows that until January 1, 2006, a plan that provides either a separate prescription drug benefit or a prescription drug rider not meeting the HDHP deductible minimums will not preclude an otherwise eligible individual from making an allowable HSA contribution
20. www.fiducial.com 20 HSA’s What other coverage is allowed? Miscellaneous coverage that won’t disqualify an individual
The following won’t disqualify an individual:
Mere eligibility for low-deductible coverage
Certain discount cards and discounted prices
So long as plan does not pay any benefits before deductible
Query about cards with huge discounts
Must carefully tailor other benefits to meet exceptions:
EAP, wellness programs or disease management programs
On-site clinics
Executive reimbursement plans
Employer responsible for knowing about employer-provided coverage – HDHP and non-HDHP
21. www.fiducial.com 21 Designing FSA to work with HSA What health FSA coverage is HSA compatible?
Some health FSA designs prevent HSA eligibility
Traditional wide-open health FSA coverage makes an individual ineligible for an HSA
It is impermissible non-HDHP coverage
Health FSAs can be designed to limit categories of expenses that can be reimbursed and/or the individuals whose expenses can be reimbursed
22. www.fiducial.com 22 Designing FSAs to work with HSA What health FSA coverage is HSA compatible?
Some designs will not prevent HSA eligibility
Limited purpose health FSA
High-deductible health FSA
Should Ask:
Is it a traditional health FSA (not limited-purpose)?
Is coverage limited to just spouse, or spouse and dependents?
23. www.fiducial.com 23 Designing FSAs to work with HSA Limited-purpose health FSAs
Types:
Vision
Dental
Preventive care
Mix and match
Problems with limited-purpose health FSAs
Administering preventive care
24. www.fiducial.com 24 Designing FSAs with HSA High-deductible health FSAs
A high deductible health FSA is one that does not pay or reimburse any medical expense incurred before the minimum annual HDHP deductible is satisfied
$1,000 for self-only
$2,000 for family
The deductible for the health FSA (other coverage) need not be the same as the deductible for the HDHP, but in no event may the HDHP or other coverage provide benefits before the minimum annual HSA deductible is satisfied
If the HDHP and the other coverage do not have identical deductibles, contributions to the HSA are limited to the lower of the deductibles
25. www.fiducial.com 25 Design Rules No Double Dipping
Employer offering both health FSA and HSA must advise employees that the same expense cannot be used to claim reimbursement from the health FSA and HSA
Employer cannot restrict use of HSA funds
HSA shoebox rule opens door for abuse
May retain funds in HSA for years and then take distributions
No time limit on when distribution must occur
An individual who has an HSA balance and becomes covered by a traditional health FSA becomes ineligible to make future HSA contributions but still can use up HSA balance
Caution: Record keeping is critical
26. www.fiducial.com 26 Lessons Learned When offering HSA Plan:
Change Plan Designs and Require “Active” Enrollment
Make conscious decision about health care plan during open enrollment
Communicate information Early and in Stages
Communicate, communicate, communicate
Provide Education Support to Help Employees Evaluate Choices
Ex. Cost calculators
27. www.fiducial.com 27 Plan Administration Develop a strategy to determine how HSA’s fit in your organization’s long term goals
Gain support from senior management and front line management
Provide some level of employer contribution
Model designs to determine impact on various groups of employees
Work closely with your health plan carrier to understand administrative details
28. www.fiducial.com 28 Contact Information Human Resource Department1370 Avenue of the Americas
31st Floor, New York, NY 10019
Phone: 212-207-4700 Ext. 103
Hr@fiducial.com
Fax: 212-308-3613
29. www.fiducial.com Thank You!