Exchange Board Consultant & Members View of a “Meaningful” Tax Credit

At the CT Health Insurance Exchange meeting on Dec 15, both the consultant and some Board members stated that the current federal Tax Credit available to Small Businesses from 2010 through 2015 is not meaningful enough for employers to motivate employers to enter the Exchange in 2014 for the tax credit.  Simply explained, they are implying that an employer will not bother to purchase their employee benefits through the Exchange, because the tax credit isn’t worth their time.  This also assumes that small employers also have no interest in letting their low income employees get federal tax subsidies to offset their share of the premium payments.

Therefore, this author decided to run some scenarios using available online tax calculators.   I am not a tax advisor, so these examples are for reference.  In having attended a seminar by an IRS representative recently, it makes one question what assumptions the consultant made in their calculations.   Important items to note that were pointed out during the seminar; 1) owners and family members, including extended family, are not included in the tax credit calculation; and 2) the numbers are based of FTE’s, meaning part-time employee hours worked are combined to create full-time equivalent employees.   As any small business owner knows, excluding family; and including lower wage part-time employees in this type of calculation actually increases the ability to qualify for the tax credit and the amount of the tax credit.

The tax credit has been available since 2010 and allows a for-profit business the option of a five-year carryback, but the credit can only offset actual earnings.  For Non-Profits, the tax credit is reduced, but it is also refundable.  The tax credit is available to employers with up-to 25 FTE’s, so we are primarily discussing the small locally owned and operated business in our own communities.  The following examples assume full time employees with average employee wage of $15/hour, working 40 hours/week, 52 weeks/year and that the average cost of the health insurance premium to the employer is $8,000/employee.  The $8,000/employee is based on a 2/3 to 1/3 ratio of employee only plans to family coverage plans with annual premiums of $6,000 and $12,000, respectively; and that the employer pays 50% of the premium cost of the health insurance.  Based on many years of working with these size employers, these are very realistic numbers.

For a for-profit employer:

3 FT Employees; Estimated Annual Tax Credit 2010-2013 = $3,192, and for 2014/2015 = $4,560.

9 FT Employees; Estimated Annual Tax Credit 2010-2013 = $9,576 and for 2014/2015 = $13,680.

18 FT Employees; Estimated Annual Tax Credit 2010-2013 = $5,712, and for 2014/2015 = $8,160.

For a non-profit employer:

3 FT Employees; Estimated Annual Tax Credit 2010-2013 = $2,160, and for 2014/2015 = $3,024.

9 FT Employees; Estimated Annual Tax Credit 2010-2013 = $6,840, and for 2014/2015 = $9,576.

18 FT Employees; Estimated Annual Tax Credit 2010-2013 = $4,080, and for 2014/2015 = $5,712.

The above numbers are estimates and an accountant would have to verify the actual numbers on a case-by-case basis.  However, if you are a small employer, I am certain that you can relate to the above numbers.  Therefore, if reasonable health insurance plans, similar to today’s plans, are actually available on the Exchange; I believe all employers that qualify for the credit will try and purchase their benefits through the Exchange.  Simply put, I don’t know too many small business owners that have $1,000’s to burn!   It is absolute proof that the consultant and some board members are completely disconnected from the struggles of a small business owner!!!  Do they not understand that $500 to $1,000 per month, as estimated above, is the difference between making payroll or not; or, keeping the electricity on or not; or, paying this month’s rent or not!  Seriously, do they really understand small business?  And, can we trust them to do what’s in the best interest of small businesses???

Tony Pinto 

Mercer finishes report to Exchange Board

Mercer’s analysis predicts that exercising the Basic Health Plan Option would save CT between $145 and $30 per member per month. The Basic Health Option was created in the Affordable Care Act; Mercer estimates that 74,000 people in CT would be eligible. The option allows states to enroll residents just above Medicaid eligibility levels to 200% of the federal poverty level (now $21,780/year for an individual, $45,700 for a family of four) into a state-sponsored plan similar to Medicaid in 2014. The feds will reimburse the state 95% of the cost of subsidies those consumers would have received in the insurance exchange. Up to this report, there has been some disagreement on the potential savings/costs of CT choosing the option. Advocates are concerned that without the Basic Health Plan, low-income consumers, some now in Medicaid, would be forced into lower-value, unaffordable options in the exchange. As incomes fluctuate more at lower incomes, choosing the Basic Health Option will improve continuity of care for more people in CT.

Mercer also estimates that 40,000 people will join the small business exchange and 185,000 will join as individuals. This is substantially lower than a CT estimate by RAND for the Council of State Governments using a different model. Mercer estimates that only 5% of small businesses not eligible for subsidies will purchase coverage in the exchange and that many will drop coverage entirely, leaving their workers in the individual market. Board members noted that employers in MA did not drop coverage during their health reforms five years ago. Mercer acknowledged that these are estimates and a great deal depends on effective outreach and public education campaigns. Again, Board members are focused on low numbers of small businesses in MA’s exchange and asking “how can we avoid mistakes made in MA.” They are missing the larger point -- since their reforms and creation of their exchange, the percent of MA small businesses offering health benefits is up, while it dropped significantly in CT during those same years.

Mercer also found little impact of incorporating CT’s high risk pools into the exchange. They estimate that merging the small group and individual markets would lower individual premiums by 2% but raise small groups’ by 4%. Again this is different than what MA experienced – individual premiums averaged 33% less after reform. Mercer also found that the individual mandate penalty makes very little difference in the number of uninsured, even if the penalty was tripled from current law. (Is this where advocates say – I told you so?)

Another Hartford Courant editorial calls on insurance exchange to add consumer voices

For the second time, the Hartford Courant’s Editorial Board has called on the health insurance exchange to add voting consumer members. “Giving consumer advocates a voice, and a vote, will almost surely further the stated goals of the exchange: to provide more health care choices, to enhance the quality of health care, to hold insurance companies more accountable and to lower health care costs.” The editorial points out that Lt. Gov. Wyman, Chair of the Exchange, believes that legislators need to change the law but “she also made the curious statement that adding consumer voices to the board ‘would do nothing less than undermine the progress Connecticut has made in becoming one of the states in the forefront of implementing this historic and much-needed reform.’" Frankly, the law is fine, a national model in conflict of interest protection, excluding any members “affiliated” with insurers. Federal regulations also state that a majority of members should represent consumers. Currently, three Board members have deep ties to the insurance industry and no voting members represent consumers. One in ten CT residents is expected to buy their coverage from the exchange. The Board is responsible for deciding which insurers will be able to sell plans in the exchange, what standards they will have to meet, what benefits they have to offer, and what they can charge.

More questions raised about insurance company rep.s on exchange board

An article in today’s CT Post raises the question of whether the administration and legislators are unable or unwilling to address widespread concerns about the make-up of the CT Health Insurance Exchange Board. The Board includes three former insurance executives, despite legislation that excludes anyone “affiliated” with insurers. The Board also has no voting consumer representatives; federal regulation states that the majority of voting members should represent consumers. Lt. Gov. Wyman, chair of the Exchange Board, defends the membership and claims that it requires legislative action to add consumer representatives. Other officials however state that consumer advocates could be added by executive order. It has been commonplace for years for non-appointed stakeholders to join the discussion on similar boards, councils and commissions at the discretion of the Chair. Engaging consumer advocates in the conversation would add a critical perspective, tap expertise that is essential to a successful exchange, help re-build public trust in the process, and might calm concerns by insurers and the administration about consumer involvement.

Former CEO of ConnectiCare believes he is a consumer advocate

In a Hartford Courant article Mickey Hebert, a controversial former insurance executive nominated to the CT insurance exchange board, maintains that he is fully capable of understanding the needs of consumers. Advocates dispute that claim, outlining important qualifications that only people who have assisted consumers meet the standard. Advocates are also skeptical that a former insurance executive can put aside his former occupation, looking out for the interests of a for-profit  insurance company, and act in consumers’ best interests, especially when the two are at odds. The state law that created the exchange includes strong conflict of interest language excluding membership on the Board by anyone “affiliated” with an insurance company. Federal regulations state that a majority of voting Board members should be consumer representatives.

More MA small businesses offer health benefits after reform, lessons for CT exchange

Massachusetts implemented sweeping health reforms in 2006, including creating a health insurance exchange – the MA Health Connector. The reforms were very successful in increasing health coverage in the state; less than 2 percent of residents are now uninsured.  The percentage of Massachusetts’s smallest businesses (under 10 workers) offering health benefits to their employees rose by 2 percent from 2005 to 2010 while the US average fell 4% and Connecticut’s rate dropped 7%. For more, read the first CT Health Insurance Exchange Watch Brief.  In recent discussions at the CT Health Insurance Exchange Board meetings, much has been made of low small business enrollment in the MA Health Connector. Board members and presenters have focused on how to make Connecticut’s exchange attractive to small businesses. But the point isn’t to build enrollment in the exchange, it is to get people and small businesses covered.  It is very possible that the MA Health Connector’s ability to offer quality products at more affordable prices placed competitive pressure on the market outside the exchange to improve options. Building a functional exchange in Connecticut can have positive effects on the rest of the market. We urge the CT Health Exchange Board to refocus on providing affordable, quality insurance options to everyone. Let the market do its work.

Small businesses ask HHS for help with CT insurance exchange

Small Business for a Healthy CT, a coalition of small companies, sent a letter yesterday asking HHS Secretary Sebelius to intervene with CT policymakers and reverse insurance industry domination of the CT Health Insurance Exchange Board. SBHCT is among at least a dozen advocacy groups that have voiced concerns about the Board membership which includes three insurance industry representatives but no voting consumer representatives and only one small business owner. The exchange is being created under national health reform with federal funding and is meant to be a consumer-friendly marketplace for coverage. It is expected that one in ten CT residents will get their coverage through the exchange. State law excludes anyone “affiliated” with insurance companies from Board membership and federal regulations state that consumer representatives should be a majority of voting members. The Board will decide which insurance plans are allowed to offer plans in the exchange, what benefits they have to offer, what standards they have to meet and how much they can charge consumers. Press reports include radio reports, CT News Junkie,  the New Haven Register, Hartford Business Journal, Public News Service, CT Mirror, and The Hill.

Advocates file ethics complaint over health insurance exchange insurance reps

A group of eight organizations, led by Citizens for Economic Opportunity and including the CT Health Policy Project, have requested an inquiry into the appointment of three members of the CT Health Insurance Exchange. The letter asserts that the appointments violate the law that created the Exchange which excludes membership by anyone “affiliated with or otherwise a representative of” insurance companies. The three members outlined in the letters have long work histories with insurers and little evidence of significant or recent experience outside the insurance industry.

Advocate and small business concerns about CT insurance exchange

Together with Small Businesses for a Healthy CT, the CT Health Policy Project has been meeting with CT Health Insurance Exchange Board members. The Board has been criticized for lacking consumer representation. Our concerns center on rebuilding public trust, effective outreach and public education, active purchasing to use the collective power of the exchange to get the best value for members, maintaining an even playing field inside and outside the exchange, a grownup conversation on mandates, and coordination with Medicaid. We are finding a lot of overlap and some of our best support is coming from unlikely sources. The Board is currently seeking a CEO.

Small businesses know health insurance exchange is a jobs issue

In a CT News Junkie opinion piece, Kevin Galvin of Small Business for a Healthy CT, wrote  -- When asked to identify their biggest challenges, small business owners in Connecticut and across the country have said that one of the greatest is the prohibitively high cost of providing health insurance. CT cannot become a business-friendly state without addressing the difficulty of insuring workers. He also notes that the insurer-dominated CT Health Insurance Exchange Board does not inspire confidence. He calls for the addition of consumer and small business representatives to that Board, as does proposed federal regulation. He calls on the Governor and General Assembly to include those representatives in the upcoming jobs bill and special session.

Editorials support consumer representation on CT health insurance exchange

The Hartford Courant and the New Haven Register have both run editorials calling on policymakers to add consumer and small business representatives to the CT Health Insurance Exchange Board. Advocates have raised concerns about insurance industry dominance in the Board membership and the lack of consumer and small business representation. One in ten state residents are expected to rely on the exchange to purchase coverage in 2014 when the federal individual mandate becomes effective. An estimated 140,000 state residents will have no choice but to purchase coverage in the exchange to access affordability subsidies. The Board will make important decisions about which plans are included in the exchange, how much they can charge, and what services they will cover. Consumer voices must be at the table, with a vote.

Insurance Exchange Board members dominated by insurance interests, no consumer representatives

Members of CT Health Insurance Exchange Board were announced in August. Despite federal law calling for a majority of members to represent consumers, there are no consumer advocate voting members. (Thankfully Vicki Veltri, State Health Care Advocate, will sit at the table but cannot vote.) In addition, three members have long ties to insurance companies as recent employees. This is despite CT law barring members affiliated with insurers, among others, in strong conflict of interest language that has been a beacon among states. Advocates are concerned that representatives of the insurance industry lobbied hard to stop passage of health reform in Washington but are now placed in charge of implementing it here in CT. One in ten state residents are expected to rely on the exchange to purchase coverage in 2014 when the individual mandate becomes effective.  It is critical that consumers eligible for Medicaid who apply through the exchange are appropriately referred to that program rather than diverted into insurance plans in the exchange. Advocates sent a letter to members urging them to set aside insurance ties and make consumers their top priority. For press reports, click here, here, here, here, here and here.

Advocates urge CT Health Insurance Exchange Board members to consider consumers’ needs

In an August letter to the newly appointed members of the CT Health Insurance Exchange Board, eleven consumer advocacy organizations offered to help in their important work and urged the members to keep the needs of consumers in mind in all decisions. The insurance exchange was created in response to national health reform; most states are taking the option to create their own exchange with federal start up funding. The exchange was designed to provide CT consumers and small businesses with a rational, fair marketplace to purchase health insurance. It is critical that this market be a trusted credible source for consumers who will be required to purchase health insurance in 2014. It is estimated that one in ten state residents will secure coverage through the exchange by 2016 including 140,000 eligible for federal premium subsidies who will be required to purchase coverage through the exchange. The Board will have a number of difficult and controversial decisions to make including whether to allow any willing insurer to participate, as Utah has chosen, or actively purchase coverage to get the best deal for consumers, the Massachusetts model. The Board will have to decide which state mandates, if any, beyond the federal essential benefit package (EBP) to require of exchange plans, with the state likely paying the cost for those benefits. The proposed EBP is expected to be announced this fall. The Board will have to decide whether to create separate exchanges for individuals and for small businesses, whether to merge the small group and individual markets, and hire staff to run the exchange. CT’s law creating the exchange included very strong conflict of interest language supported by advocates, excluding people currently affiliated with the insurance industry among others. We expect that all members will honor the spirit of the law, regardless of background.