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Health Care Reform - Clinton
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Originally Processed With FOIA(s): FOIA Number: 1999-0118-F 1999-0118-F FOIA MARKER This is not a textual record. This is used as an administrative marker by the George Bush Presidential Library Staff. Record Group/Collection: George H.W. Bush Presidential Records Collection/Office of Origin: Policy Development, White House Office of Series: Kuttner, Johannes, Files Subseries: OA/ID Number: 08195 Folder ID Number: 08195-023 Folder Title: Health Care Reform - Clinton Stack: Row: Section: Shelf: Position: G 17 15 5 2 U.S. DEPARTMENT OF LABOR OF LABOR Pension and Welfare Benefits Administration UNITED STATES PATRICAL Office of the Assistant Secretary October 9, 1992 MEMORANDUM TO HANS KUTTNER GREGORY HUBBARD STEVE BANDEIAN FROM: ANN L. COMBS Attached is summary of Rep. Bill Ford's (D-MI) health care proposal. His staffer has been talking to the Clinton campaign. It may give us a better handle on some of Clinton's rhetoric. I have bill language if you are interested. Attachment UNIVERSAL MEDICAL CARE (UNIMED) ACT OF 1992 CONGRESSMAN WILLIAM D. FORD (MICHIGAN) CHAIRMAN, COMMITTEE ON EDUCATION AND LABOR U.S. HOUSE OF REPRESENTATIVES OverviewSummary A single unified system providing universal access to health insurance for all Americans through 3 component parts -- an employer mandate (Mediworkers) coverage for children (Medikids), and an element to cover adults not connected to the workforce (MediWrap). MediWorkers An employer mandate covering full-time adult employees (and spouses who do not work full-time). Employees pay no more than 20% of premium. Basic benefits (including preventive services), with a $250 individual deductible, 20 percent coinsurance, and $2,500 stop-loss, but with first-dollar coverage for pregnancy-related and preventive services. Process for premium/benefit equalization that assures employer premiums are related to payroll and health plan receipts are related to risk. Additional insurance reform (including guaranteed availability, acceptance of actuarially based premium rate, no preexisting condition exclusion) to ensure availability to all. MediKids Provides health benefits to all children under 22 years of age, regardless of familial, employment, educational, or economic status. Same benefits as in MediWorker, plus early, periodic, screening, and diagnostic services and increased mental health benefits. No deductible for kids under age 18, $150 annual deductible thereafter. No copayment for kids under 3 or for pregnancy-related or preventive services. Minimal copayment schedule for ages 3-11, 20 percent copayment ages 12-21, and $1,500 stop-loss per child. MediWrap Provides health benefits to all individuals 22 years of age or older who are not covered under MediWorker or Medicare. There would be a national-rated premium. Notwithstanding the national-rated premium, no individual's - 2 - liability could exceed the premium percentage established under the MediWorker component of UniMed times the individual's gross income. Part-time and seasonal workers would receive a credit toward this income-related cap for payments credited through employment. Same benefits as in MediWorker. Cost Containment Under MediWorkers, (1) maximum charge limits, (2) encouraged use of managed and coordinated care (through network plans, utilization review, use of practice guidelines and outcomes research), (3) local quality review boards, (4) use of uniform claims forms and electronic billing, uniform health plan cards, etc., (5) limitation on capital expenditures, and (6) initiatives toward medical malpractice reform. Under MediKids and MediWrap, (1) mandatory assignment and use of specific payment rates, (2) managed and coordinated care initiatives, (3) use of uniform claims forms and electronic billing, etc., and (4) demonstrations on medical malpractice reform. Low-Income Assistance Premiums - Employee/employer premiums related to wages (viz., lower for low-income workers). Premiums for non-worker coverage capped at a percentage of gross income. Deductible and Coinsurance - Reduction/rebate of deductibles and coinsurance for individuals with income below poverty level, with phase-out in assistance through 200 percent of poverty level. Financing MediWorker - Financed entirely through payroll-related premiums, with employees paying no more than 20% of the premium. MediKids - Financed through MediWorker payroll premium, premium on child employees, State medicaid maintenance of effort payment (with additional Federal matching revenues), and other revenue sources. MediWrap - National-rated premium (subject to income cap), (non-worker self-employment taxes), and Medicaid maintenance of effort payments. Low Income Assistance - (1) Income tax on gross income (other than wages, self-employment, and other income subject to premium or taxes under the three programs) at flat rate (of 1/5 of premium percentage), and (2) other Federal general revenues. ruary 24, 1992 UNIVERSAL MEDICAL CARE (UNIMED) ACT OF 1992 Short Overview/Summary Title/Program Summary of Policy Notes Short Title Universal Medical Care Act of 1992 or "UniMed". F:\FHBC\UNIMED.SUM UniMed Program Program administered by an independent Health Bene- fits Administration (HBA), to ensure that basic, afford- able medical care is available to all citizens, under a uni- fied, coordinated program. The MediWorker component imposes an employer mandate to provide basic insurance benefits to employees and their spouses. The MediKids component ensures that the same basic benefits (with modifications to take into account the medical needs pe- culiar to children) are extended to the children of work- eΓB and nonworkers. The MediWrap component extends basic benefits to adults who are not in the workforce. Effective: January 1, 1995. MediWorker Component An employer mandate covering full-time adult employ- MediWorker Component of UniMed will be set forth in ees (and spouses who do not work full:time). new title V of ERISA. 1 Basic benefits (including preventive services), with a $250 individual deductible, 20 percent coinsurance, and $2,500 stop-loss, but with first-dollar coverage for preg- nancy-related and preventive services. Funded by premiums paid by employers and (through withholding) by employees at a prescribed "MediWorkers national premium percentage" (MNPP) of payroll, except that employees pay no more than 20% of premium. Process for premium/benefit equalization that assures that employer and employee premiums are related to payroll and group health plan receipts are related to ac- tuarial risk. MediKids Component Provides health benefits to all children under 22 years of age, regardless of familial, employment, educational, or economic status. MediWrap Component Provides health benefits to all individuals 22 years of age or older who are not covered under MediWorker component or Medicare. Medicare Changes Reduction in age of initial eligibility from 65 to 60. February 24, 1992 MEDIWORKERS COMPONENT OF UNIMED [TITLE I] Issue/Topic Policy Notes A. EMPLOYER MANDATE MediWorker Component of UniMed will be set forth in new title V of ERISA. F:\FHBC\UNIMED.SUM Enrollment Requirement All employers are required to enroll full-time employees (and spouses who are not full-time employees) who are not children under a qualified group health plan. U.S. companies employing U.S. nationals abroad would have to meet this requirement. These plans can be insured or self-insured. Self-em- ployed individuals (with or without employees) would be covered under MediWrap component of UniMed. B. GROUP HEALTH PLAN REQUIREMENTS Summary of Requirements for All Group Health To be qualified, a group health plan must meet speci- Plans fied requirements, including- (1) providing required core benefits [see C1. below]; (2) limiting deductibles, coinsurance, and total cost- 2 sharing [see C.2-4. below]; (3) providing consumer protection (including maximum employee premiums, no preexisting condition limits, "portability" of benefits, and solvency protection); and (4) providing for equalization of premiums and capita- tion rates for core benefits. C. REQUIRED "CORE" BENEFITS C1. "Core" Services: Employers can supplement core benefits. C1. (a) Inpatient hospital services Unlimited; except limited to 45 days of inpatient men- tal health services in any year. C1. (b) Physicians' services Unlimited inpatient and outpatient physicians' services and community health clinic services (except for limit on mental health services, see below). C1. (c) Mental health services Limited to 45 days of inpatient care per year and 20 outpatient visits per year. Would treat as qualified pro- viders (for outpatient services) psychologists and clinical social workers. H.L.C. uary 24 1992 C1. (d) Alcohol and drug abuse treatment services Limited specified dollar value (viz., $5,000) in any 3- year period. C1. (e) Pregnancy-Related Services Coverage of prenatal, labor, delivery, and postnatal services, including services of certified registered nurse midwives. C1. (f) Preventive Services F.\FHBC\UNIMED.SUM Coverage of-- Screening mammography and screening pap smears (at frequency to be specified by HBA), Family planning services, & Adult immunizations. HBA to establish an advisory committee to make rec- ommendations on additional preventive benefits; HBA can add new preventive benefits if appropriate, taking into account cost, but only after providing at least 2 years' notice. C1. (g) Laboratory and Diagnostic tests Diagnostic and laboratory tests are covered. C1. (h) Case management services To be covered for people diagnosed with certain ail- ments, specified by HBA. C2. Deductible Single, per person annual deductible. 3 C2. (a) Amount $250, indexed by inflation-related increases in SSA wage base (viz., $230 contribution and benefit base). C2. (b) Exceptions Does not apply to pregnancy-related services or preven- tive services C3. Coinsurance/Copayments - C3. (a) Percentage 20 percent. C3. (b) Exceptions Does not apply to pregnancy-related services or preven- tive services. Can be greater in the case of provision of services by nonparticipating⁻ providers under qualified network plans. C4. Limit on Cost-Sharing $2,500 per person. Amount indexed by increases in SSA wage base. D. MAXIMUM CHARGE LIMITS AND MINIMUM PAYMENT RATES H.L.C. February 24, 1992 MEDIWORKERS COMPONENT OF UNIMED [TITLE I]-Continued Issue/Topic Policy Notes D1. Establishment of Reference Payment Rates In connection with the periodic establishment of the MediWorkers national premium percentage (MNPP) [see F:\FHBC\UNIMED.SUM G2 below] and using medicare payment methodology or similar prospectively determined payment methodology, HBA will set reference payment rates. HBA may, upon application by a State, permit substitu- tion of State-based rates, if (1) the rates will apply to all payors (including the MediKids and MediWrap compo- nents), (2) the rates will not result in total expenditures greater than those otherwise permitted under all the programs, and (3) will not result in a significant shifting of costs among the different components. D2. Maximum Charge Limits Institutional services.-For institutional services (viz., Maximum charge limits consistent with medicare other than professional services), the reference payment model. rates are the maximum charges that can be imposed by providers for covered services for individuals under qualified group health plans. Professional services.-For physician and other profes- sional services, the maximum charges are the same pro- portion above the reference payment rates as the limit- ing charge permitted under the medicare RB-RVS pay- ment system. Enforcement.-Violation of the charge limits would sub- ject providers to civil money penalties and exclusion under MediKids and MediWrap components of UniMed. D3. Controls on Capital Expenditures for Hospi- -Hospitals required to report annually to HBA on ex- tals penditures for capital. HBA will require justification for rates of increase in capital costs identified as excessive. The HBA will reduce, prospectively, the maximum charge limits for hospital services to the extent the iden- tified excessive rate of increase in capital expenditures has not been justified. H.L.C. ebruary 24, 1992 E. EMPLOYEE & CONSUMER PROTECTIONS These would include (1) limiting employee premiums to 20% of MNPP, (2) prohibiting use of preexisting condi- tion restriction on basic benefits, (3) enrollee protection against plan insolvency, (4) standardization of health plans cards and health claims forms, and (5) protections for emergency out-of-plan coverage in the case of net- F:\FHBC\UNIMED.SUM work plans (such as HMO's). F. ADDITIONAL REQUIREMENTS FOR INSURED Also, insured plans must also meet requirements relat- PLANS ing to (1) guaranteed availability of basic benefit plans for all employers (without regard to size) in a State, (2) guaranteed renewability (except for cause), (3) requiring the offering of basic benefit plans (with preemption of State benefit mandates), & (4) limitation on premium to the MNPP of wages. G. PREMIUM EQUALIZATION PROCESS G1. Summary/Overview -(1) Employers effectively pay premiums based on a percent of payroll. [This provides inter-employer equity.] -(2) Group health plans, after "equalization", effective- ly receive a netted "actuarial" premium based on the de- 5 mographic characteristics of individuals enrolled. [This provides inter-insurer equity and provides opportunity (and therefore incentive) for health plans to contain costs.] Since health plans are not paid based on actual cost, employees, employers, and plans may "profit" from containing costs (either through managed care or pre- ferred provider arrangements or through employer/em- ployee wellness programs, or other means). G2. Specification of Employer Premiums (MediWorkers National Premium Percentage (MNPP)) H.L.C. February 24, 1992 MEDIWORKERS COMPONENT OF UNIMED [TITLE I]-Continued Issue/Topic Policy Notes G2. (a) In general Employers (other than those that are meeting mandate through self-insurance), pay a premium for basic benefits F:\FHBC\UNIMED.SUM equal to a percentage (periodically adjusted by HBA) of payroll to the qualified plan. This percentage is referred to as the MediWorkers National Premium Percentage or "MNPP". Plans of self-insured employers are treated the same as insured plans for purposes of "equalization" of payable premiums to benefits to be provided. Payroll subject to MNPP would be capped for each worker at twice the maximum wages subject to the So- cial Security tax. G2. (b) Computation of MediWorkers National Premium -Establishment of initial MNPP. The MediWorkers Na- Percentage (MNPP) tional Premium Percentage (MNPP) of payroll for 1st year only (viz., 1995) will be specified in the statute. Subsequent MNPP.HBA will adjust the MNPP each 6 year to reflect changes in health care costs relative to payroll. HBA must set the MNPP high enough to cover all expenses. HBA will take into account efficiencies re- sulting from medical care innovations as well as new technologies. H.L.C. ebruary 24, 1992 G3. Requirement of Equalization -Equalization Premiums Payable to FHBEC.-Each qualified group health plan (including self-insured em- ployers and Taft-Hartley plans) must pay to the Federal Health Benefits Equalization Corporation (FHBEC, which is within the Health Benefits Administration) an amount equal to the amount by which (A) the employer F:\FHBC\UNIMED.SUM premiums (viz., computed as an HBA-specified percent of payroll) exceed (B) the "capitation amount" [see G4 below] for all individuals covered under the plan. Equalization Rebates Paid by FHBEC-FHBEC must pay each group health plan (including self-insured em- ployers and Taft-Hartley plans) an amount equal to the amount by which (A) the employer premiums (viz., per- cent of payroll) [see G3 below] are less than (B) the "capi- tation amount" [see G4 below] for all individuals covered under the plan. G4. Computation of Capitation Amounts G4. (a) Summary The capitation amount, which is used by FHBEC as a reference rate for the amount employer plans should have received for basic benefits, for an individual is 7 equal to the product of a base rate (common to all indi- viduals) and the weighting factors (for the actuarial class to which the individual is assigned). The base rate and weighting factors (as well as actuarial classes) are estab- lished by the HBA under the process described below. G4. (b) Establishment of Actuarial Classes The HBA shall assign individuals covered under quali- fied group health plans to "actuarial classes". These classes are established by the HBA, based on a combina- tion of age, sex, disability status, area of residence, and other appropriate factors, and would be actuarially sound. The HBA shall establish the minimum number of actuarial classes and shall not provide for disease-specif- ic or condition-specific classifications. H.L.C. February 24, 1992 MEDIWORKERS COMPONENT OF UNIMED [TITLE I]-Continued Issue/Topic Policy Notes G4. (c) Computation of Relative Weight for Each Actuar- Using sample data supplied by FHBEC in its work, the F:\FHBC\UNIMED.SUM ial Class HBA computes "weighting factors" that reflect the rela- tive costs of each actuarial class compared to the average for all the classes. HBA would obtain information, on covered individuals by social security number only, on plan enrollment, age, sex, and other relevant actuarial characteristics neces- sary to assign accurate weighting factors for each indi- vidual. Privacy Act protections would apply to restrict use and disclosure of the information. There would be a one-time collection of information, with periodic adjust- ment. The information would only be used for purposes of capitation payment computations. G4. (d) Computation of National Average Expenditures The FHBEC would compute each year, based on the (Base Rate) MediWorkers national payroll percentage (MNPP), a na- tional average per capita amount of.expenditures ("base 8 rate") for basic health care services under all qualified group health plans (including self-insured plans). This base rate would be based on formula: (A) total projected payroll for MediWorkers covered individuals subject to MediWorkers premiums, times (B) MNPP, divided by (C) average number of covered individuals under MediWorkers component of UniMed. G4. (e) Computation of Capitation Amount For each individual in an actuarial class, the "capita- tion amount" would be the product of the national aver- age expenditures and the weighting factor for the class. G5. Transitional Premium Subsidy for Small Busi- Businesses with 25 or fewer employees would be eligi- ness ble for a subsidy to reduce the employer share of MediWorker premiums. The subsidy would begin at 50% of the employer share in 1995, and be phased down to be 37.5%, 25%, & 12.5% in 1996, 1997, & 1998. H. ENFORCEMENT AND RELATED ADMINISTRA- TIVE ISSUES H.L.C. Enforcement of employee's rights under group -After exhausting plan's own claims review proce- health plans through Special Counsel and Group dures, employees may bring complaints to a Special Health Plan Review Board Counsel of HBA, who will attempt to resolve disputes in Early Resolution Program (ERP). -Under the ERP process there will be facilitators to eliminate misunderstandings, clarify issues, and identify F:\FHBC\UNIMED.SUM settlement options and assist in encouraging settlement of disputes. However, neither party waives the right to further adjudication of issues at conclusion of ERP proc- ess. -Special Counsel or employee may bring disputes left unresolved by ERP to administrative review before ALJ of the Group Health Plan Review Board (GHPRB), sub- ject to court review in Federal Circuit Court of Appeals of appropriate Circuit. I. MISCELLANEOUS 11. Preemption of State provisions 11. (a) Preemption of State Benefits Mandates State law cannot require benefits other than the basic required benefits. 6 11. (b) Preemption of State Restrictions on Managed Care State cannot impose certain restrictions on bona fide network plans nor on proper utilization review pro- grams. 12. Repeal of COBRA continuation requirements COBRA continuation coverage requirements are superceded by UniMed and are therefore repealed. 13. Increase Deduction for expenses for self-em- Would extend current 25% deduction through 1/1/95; as ployed of that date would increase to 100%, but limit to ex- penses for required health benefits only. H.L.C. February 24, 1992 MEDIKIDS COMPONENT OF UNIMED [TITLE II] Issue/Topic Policy Notes A. ELIGIBILITY/ENTITLEMENT Extension of MediWorkers component, providing cover- F:\FHBC\UNIMED.SUM age to all children residing in the U.S. who are under 22 years of age, regardless of employment or education sta- tus. Enrollment at birth or time of immigration; enrollment not prerequisite to receive services or benefits. B. REQUIRED BENEFITS Employer's group health plan can supplement benefits; but benefits under MediKids component are primary. B1. Services B1. (a) Basic Services Except as specified, would include the MediWorkers "core" service package, including- -inpatient hospital services (subject to 45 day annual limit for inpatient mental health services), except that preadmission authorization would be required for inpa- tient mental health services and no admission would be 10 approved if could adequately treat as an outpatient; -physicians services and community health clinic serv- ices; -mental health services (but with outpatient limit of 40 visits per year, rather than 20 under MediWorkers component of UniMed); -alcohol and drug abuse treatment services; -pregnancy-related services; -laboratory and diagnostic tests; & -case management services. H.L.C. lary 24, 1992 B1. (b) Authonal MediKids Services Would include the following additional services (subject to a periodicity schedule established by HBA in consulta- tion with the American Academy of Pediatrics): -periodic screening services, including comprehensive physical examinations, age appropriate immunizations, laboratory tests, and health education; F:\FHBC\UNIMED.SUM -vision services, including screening and corrective eyeglasses or lenses; -dental services, including screening and preventive dental and corrective dental services; and aids. -hearing services, including screening and hearing Would also include prescription drugs, including insulin and medically appropriate nutritional supplements. Would also include the föllowing (if part of plan of care prescribed by a physician): -treatment of developmental and learning disabilities (other than the educational component); and -speech, occupational, and physical therapy. HBA would examine (and report to Congress) concerning the appropriateness of providing coverage for long-term 11 care services under the MediKids component of UniMed. B2. Deductible Under age 18, none would apply. At age 18, there would be a deductible of $150, indexed to SSA wage base (as with MediWorkers' deductible) B3. Coinsurance None for children under 3 or for pregnancy-related services or preventive services. For other services, copayment schedule for children 3- 11 (i.e., $5 per outpatient visit) and 20 percent coinsur- ance for children 12 and older. B4. Limit on Cost-Sharing $1,500 per kid, indexed by increases in SSA wage base. C. PAYMENTS FOR SERVICES Single payor-model (like medicare). H.L.C. February 24, 1992 MEDIKIDS COMPONENT OF UNIMED [TITLE II]-Continued Issue/Topic Policy Notes C1. Payment Rates HBA to establish payment rates based on reference payment rates established under MediWorkers compo- F:\FHBC\UNIMED.SUM nent of UniMed, with appropriate modifications to reflect children-only coverage under the MediKids component. For services not covered, will establish appropriate schedule based on concepts used in establishing MediWorkers reference payment rates. C2. Payment Method Assignment is mandatory. D. MISCELLANEOUS D1. Funding Financing for MediWorkers children through MediWorkers premiums. (See B1 under Financing [Title VI]) and for MediWrap children through addition to MediWrap premiums (see C1 under Financing [Title VI]). D2. Use of Intermediaries As in medicare, except HBA would do the contracting 12 for fiscal administration. Would permit States to admin- ister. D3. Treatment of HMO's and Capitation HBA would be authorized to contract with HMO's under a capitation contract in manner similar to author- ity of HHS to contract on a risk basis with HMO's under the medicare program. D4. Relation to Medicare & Medicaid Programs Primary payor to medicare and medicaid programs. States would be required to maintain effort in terms of eligibility and benefits for children (above those provided under MediKids component of UniMed). This would not duplicate low-income assistance. H.L.C. bruary 24, 1992 MEDIWRAP COMPONENT OF UNIMED [TITLE III] Issue/Topic Policy Notes A. ELIGIBILITY/ENTITLEMENT All legal permanent residents aged 22 through 59 who cannot establish coverage under medicare (as disabled) F:\FHBC\UNIMED.SUM or under a qualified employer health plan (as a full-time employee or spouse). B. BENEFITS (including deductibles, coinsurance, etc.) [Same as basic services under MediWorkers component] Employers can supplement benefits for part-time and seasonal workers. C. PAYMENTS FOR SERVICES Single payor model (like medicare). C1. Payment Rates HBA to establish payment rates based on reference payment rates established under MediWorker component of UniMed, with appropriate modifications to reflect pop- ulation covered under the MediWrap component. C2. Payment Method Assignment is mandatory. D. MISCELLANEOUS D1. Premiums There would be a monthly actuarially determined na- 13 tional community-rated premium subject to an income related cap. Part-time and seasonal employees would re- ceive credit for both the employer and employee amounts of the UniMed part-time/seasonal payroll tax paid, as well as any part of the Health Care equalization self-em- ployment tax paid. D2. Use of Intermediaries As in medicare, except HBA would do the contracting for fiscal administration. Would permit States to admin- ister. D3. Treatment of HMO's HBA would be authorized to contract with HMO's under risk-based contract in manner comparable to au- thority of HHS to contract with HMO's under medicare program. D4. Relation to Medicaid Program Primary payor to medicaid. Medicaid could supplement these benefits. H.L.C. February 24, 1992 COST CONTAINMENT AND QUALITY CONTROL [TITLE IV] Issue/Topic Policy Notes A. COST CONTROL MECHANISMS Costs to employers are controlled through premiums F:\FHBC\UNIMED.SUM based on the MNPP of UniMed wages and capitation payments to qualified group health plans. Al. Prices & Capital Expenditures Payment levels to providers are restricted through use of maximum charge levels under the MediWorker compo- nent and through mandatory assignment under the MediKids and MediWrap components. Control over capital expenditures through reduction in maximum charges to reflect excessive increases in cap- ital expenditures by hospitals. A2. Encouraging "Managed" or "Coordinated" Care Encouraging the use of "managed" or "coordinated" care through MediWorker payments to plans based on capita- tion, preemption of State anti-manged care laws, pay- ments to network plans under MediKids and MediWrap components, and increasing Federal funding for out- comes research. 14 B. QUALITY CONTROL MECHANISMS B1. National Standards To counter-balance the significant incentives that capi- tation provides for cutting costs, HBA would establish national quality standards, including standards to moni- tor the use of preauthorization review and other utiliza- tion review and network controls, and financial solvency standards. B2. Local Quality Review Advisory Bodies HBA would provide for establishment of local quality review monitoring advisory bodies, with representation of employers, labor organizations, and individuals, to ob- tain locality-specific, non-individually-specific informa- tion on utilization and quality of services under different plans in a community or service area, and to provide feedback to plan sponsors, the HBA, employers, and labor organizations. C.IMPROVEMENTS IN ADMINISTRATIVE EFFI- CIENCY H.L.C. Jary 24, 1992 C1. Unitorm Claims Forms & Electronic Billing All plans would have to use a uniform claims form and, as may be required by the HBA, uniform electronic bill- ing standards. C2. Uniform Health Care Cards Health care enrollment cards would have to be electron- ically coded for uniform input, as prescribed by HBA. F:\FHBC\UNIMED.SUM D. MEDICAL MALPRACTICE REFORM HBA would report to Congress on specific steps (such as the use of early resolution process under the MediWorker program as a means of alternative dispute resolution) that could be taken to improve system. 15 H.L.C. February 24, 1992 LOW-INCOME ASSISTANCE [TITLE V] Issue/Topic Policy Notes DEDUCTIBLES AND COINSURANCE ASSISTANCE Throughout the UniMed Program (comprising MediWorkers, MediKids, and MediWrap components), F:\FHBC\UNIMED.SUM assistance for deductibles and coinsurance for required services would be based on adjusted gross income (in- cluding joint income for couple). There would be no deductibles and coinsurance for those with income below 100 percent of poverty line; the deductibles and coinsur- ance would be phased out until there is no low-income assistance for individuals with income above 200 percent of the poverty level. 16 H.L.C. ruary 24, 1992 FINANCING [TITLE VI] Issue/Topic Policy Notes A. MEDIWORKERS COMPONENT OF UNIMED: Employer pays a total premium to health plan based on The funding of the transitional premium subsidy for Use of Payroll-Based premium the MediWorkers National Premium Percentage (MNPP) small business, would come from other Federal revenues. \FHBC\UNIMED.SUM of total payroll computed by HBA. However, the wages counted cannot exceed twice the maximum wage level subject to Social Security taxes (approx. $125,000). Employer may charge the employee based on a percent- age of wages (but percentage may not be greater than 1/15 of the MNPP specified by HBA). B1. MediKids Element of the MediWorkers National In recognition of coverage to be provided under UniMed Premium Percentage (MNPP) to workers' children, the MNPP paid to group health plans under the MediWorkers component would include a portion to be directed to funding the MediKids compo- nent. B1. (a) Determination of Aggregate Amount to be Collect- HBA would estimate the total cost for the year under ed Through Premium the MediKids component for children of adults covered under MediWorker component. 17 B1. (b) Payment of MediWorkers National Premium In setting the appropriate level of the MNPP, the HBA Percentage under MediWorkers Component as Element would add a percentage determined to be required to of Funding for MediKids Component raise the MediWorkers element of funding MediKids computed under B1.(a) above. In applying the MNPP 80 computed under the MediWorkers component, this additional element of funding for the MediKids component would automatical- ly be shared 80/20 between the employer and employees. B2. MediKids Element of MediWrap Premium This element would not apply to children whose parents are full-time workers because the parents pay premiums for their children through the MediWorker program. H.L.C. February 24, 1992 FINANCING [TITLE VI]-Continued Issue/Topic Policy Notes B2. (a) Amount of Flat Monthly Premium Element As part of the MediWrap premium for individuals who are not covered through the MediWorker component and F:\FHBC\UNIMED.SUM who have a child covered under MediKids, there would be a MediKids premium element equal to a nationally specified community-rated actuarial premium to be es- tablished by HBA for each child under the MediKids component of UniMed. There would be no variation by age, sex, marital status, etc. The premium component would be computed on a monthly basis (as is the case for the MediWrap premium for adults). B2. (b) Payment of Premium Element Parents would be required to pay the premium element each year in conjunction with the payment of the MediWrap premium. A8 with the MediWrap premium, parents would receive a credit for employer/employee equalization premiums paid and low-income assistance would be available to eliminate or reduce the premium element. 18 B3. State Medicaid "Maintenance of Effort" Pay- States are required to pay the MediKids component a ment "maintenance of effort" amount. B4. Treatment of Workers under Age 22 There would be a payroll-based "equalization" tax com- This would treat wages of child workers the same as puted for workers under age 22 equal to the the wages of adult workers. MediWorkers National Premium Percentage (MNPP) of their wages. The tax would have a ceiling of twice the maximum level of wages subject to the Social Security tax. B5. Additional Federal Funds Additional Federal funds would come from previous general revenues dedicated to medicaid and from other taxes (to be specified). C. MEDIWRAP COMPONENT OF UNIMED C1. Actuarial Premium Collected Through In- come-Tax System H.L.C. ebruary 24. 1992 C1. (a) Amount of Premiums Nationally specified community-rated monthly actuarial In the case of MediWrap beneficiaries with children, premium to be established for each individual (no family the amount of the premium would be increased to in- premium). There would be no variation by age, sex, mar- clude a MediKids element. See B2(a) above. ital status, etc. C1. (b) Limit on Amount of Premium to MNPP of In order to provide protection to low-income individuals, F:\FHBC\UNIMED.SUM Total, Gross Income the MediWrap premium (including any MediKids ele- ment) could not exceed the MediWorkers National Pre- mium Percentage (MNPP) of total, groes income (includ- ing joint income for a married couple and any children's income). C1. (c) Crediting MediKids and MediWrap Equaliza- There would be credited against MediWrap premium tion Employment Taxes and MediWrap Self-Employment amount (including any MediKids element), total Taxes MediWrap and MediKids equalization taxes paid (includ- ing both employer and employee shares). C1. (d) Collection To be paid with income taxes (including provision in es- timated taxes). C2. State Medicaid "Maintenance of Effort" Pay- States are required to pay the MediWrap component of ment UniMed a "maintenance of effort" amount. 19 C3. MediWrap Employment Equalization Tax for There would be a payroll-based "equalization" tax com- This would treat wages of part-time and seasonal work- Part-Time and Seasonal Workers puted for part-time and seasonal workers, equal to the ers the same as the wages of adult workers. An employer MediWorkers National Premium Percentage (MNPP), in- may pay all or a portion of the employee's share of the cluding the MediKids element, of their wages. The tax payroll-based tax, and (as under the MediWorker compo- would have a ceiling of twice the maximum level of nent) this payment would not be included in income of wages subject to the Social Security tax (approx. the employee. $125,000). C4. MediWrap Tax on Self-Employment Income Tax on self-employment income, equal to the This assures that self-employment income is not treat- MediWorkers National Premium Percentage (MNPP) (up ed more favorably than wage income. to twice the maximum wages subject to Social Security taxes, viz., approx. $125,000). This is non-refundable. C5. Source of Additional Federal Funds Remaining Federal funds would come from previous general revenues dedicated to medicaid and from other sources (to be specified). D. MEDICARE PROGRAM ELIGIBILITY EXPAN- Increase cap on HI part of FICA & SECA tax to extent SION necessary to fund expenses for expanded eligibility. H.L.C. February 24, 1992 FINANCING [TITLE VI]-Continued Issue/Topic Policy Notes E. LOW-INCOME ASSISTANCE (COVERING LOW- Addition to income tax at flat rate of 1/5 of the INCOME EMPLOYEES, CHILDREN, AND OTHERS) MediWorkers National Premium Percentage (MNPP). F:\FHBC\UNIMED.SUM However, wages, self-employment income and other in- come, to the extent a UniMed premium has been com- puted based on such income, would not be subject to this additional tax. 20 H.L.C. ruary 24, 1992 OVERALL ADMINISTRATION [TITLE VII] Issue/Topic Policy Notes Health Benefits Administration (HBA) Health Benefits Administration (HBA), headed by 15- member bipartisan board appointed from private sector \FHBC\UNIMED.SUM by President with Senate confirmation, 6-year staggered terms. 3 appointed from each of the following: labor; em- ployers; medical community, insurance community, consumer representatives. The HBA would administer UniMed through a variety of entities: -The Federal Health Benefits Equalization Corpora- tion (FHBEC), a corporate entity established in the HBA and with structure and powers similar to the Pension Benefit Guaranty Corporation (PBGC), would be respon- sible for assessment, collection, and distribution of pre- mium equalization payments from and to qualified group health plans. An Office of the Special Counsel, appointed by the President subject to Senate confirmation, with responsi- bility for encouraging early resolution of disputes and 21 enforcement of the Act. An Early Resolution Program (ERP) Office to develop program procedures, conduct case intake, maintain ros- ter of "facilitators", and otherwise carry out the ERP pro- gram. A Group Health Plan Review Board (GHPRB), consist- ing of 9 members appointed by President with Senate confirmation and similar to OSHRC, to appoint ALJ's to hear complaints of participants and beneficiaries not re- solved through ERP. H.L.C. February 24, 1992 MEDICARE REVISIONS & MISCELLANEOUS PROVISIONS [TITLES VIII & IX] Issue/Topic Policy Notes A. REDUCTION IN AGE OF MEDICARE ELIGIBIL- Reduce, as of January 1, 1995, age of initial eligibility to ITY 60. F:\FHBC\UNIMED.SUM B. MISCELLANEOUS PROVISIONS 1. Repeal of COBRA Continuation Provisions Effective January 1, 1995, repeal the COBRA continu- ation requirements contained in ERISA, the IRC, and the PHSA. 2. Grant Program for Expansion of Federally Quali- Provide an authorization of appropriations of an addi- fied Health Centers tional $400, $800, $1200, $1600, and $1,600 millions in fiscal years 1993 through 1997 for expansion of services to medically underserved individuals by Federally quali- fied health centers. 22 H.L.C. February 20. 1992 (12:50 p.m.) UNIVERSAL MEDICAL CARE (UNIMED) ACT OF 1992 Overview/Summary Title/Program Summary of Policy Notes F:\FHBC\UNIMED Short Title Universal Medical Care Act of 1992 or "UniMed". UniMed Program Program administered by an independent Health Bene- fits Administration (HBA), to ensure that basic, afford- able medical care is available to all citizens, under a uni- fied, coordinated program. The MediWorker component imposes an employer mandate to provide basic insurance benefits to employees and their spouses. The MediKids component ensures that the same basic benefits (with modifications to take into account the medical needs pe- culiar to children) are extended to the children of work- ers and nonworkers. the MediWrup component extends basic benefits to adults who are not in the workforce. Title I. MediWorker Component An employer mandate covering full-time adult employ. ees (and вроивев who do not work full-time). Basic benefits (including preventive services), with a 1 $250 individual deductible, 20 percent coinsurance, and $2,500 stop-loss, but with first-dollar coverage for preg- nancy-related and preventive services. Funded by premiums paid by employers and (through withholding) by employees at " prescribed "MediWorkers national premium percentage" (MNPP) of payroll, except that employees pay no more than 20% of premium. Process for premium/benefit equalization that assures that employer and employee premiums are related to payroll and health plan receipts are related to actuarial risk. Additional insurance reform (including guaranteed availability, acceptance of actuarially based premium rate, no preexisting condition exclusion) to promote availability to all employers and employees. Effective: January 1, 1995. ary 20, 1992 (12:50 p.m.) UNIVERSAL MEDICAL CARE (UNIMED) ACT OF 1992-Continued Overview/Summary Title/Program Summary of Policy Notes FHBC\UNIMED Title II. MediKids Component Extension of the MediWorker component, providing health benefits not only to workers' children, but to all children under 22 years of age, regardless of familial, employment, educational, or economic status. Same benefits as under McdiWorker component, but adding additional preventive benefits, prescription drugs, and certain therapeutic services, increasing outpatient mental health benefits, and decreasing cost-sharing for the youngest. Funding for MediKids component of UniMed derived substantially through premium payments integrated under MediWorker component, to the extent that HBA determines such integration necessary for maintenance of effort in relation to existing practices in the work. place. Remainder of funding derived from States under maintenance of effort determined in relation to existing 2 medicaid assistance, from payroll Laxes on workers under age 22 (and who therefore do not qualify for cover- age under MediWorkers component), and from additional general revenues, including Federal funds from previous general revenues dedicated to medicaid. Effective: January 1, 1995. Title III. MediWrap Component Further extension of MediWorkers component, provid- ing health benefits to all individuals 22 years of age or older who are not covered under MediWorker component or Medicare. Same benefits as in MediWorkers component. Funded through a national community-related premi- um, subject to a low-income assistance cap set at a per- cent of income. Effective: January 1, 1995. February 20, 1992 (12:50 p.m.) Title IV. Cost Containment Cost containment features integrated throughout UniMed Program, such as (1) encouraging use of "man- aged" or "coordinated" care (through HMO's, ulilization review, use of practice guidelines and outcomes re- F:\FHBC\UNIMED F:\FHBC\ UNIMED search), (2) use of uniform claims forms and uniform health plan cards, and (3) initiatives toward medical malpractice reform. Based in the MediWorkers component, UniMed Pro- gram will provide for (1) payment of health plans based on actuarial capitation, thus fostering competition, (2) maximum charge limits (based on medicare payment methodology), and (3) locally-based quality monitoring to ensure full availability of services and providers. Under MediKids and MediWrap components, UniMed Program will also provide for mandatory assignment and use of specific payment rates. Title V. Low-Income Assistance Premiums.-McdiWorkers component employee premi- ums related to wages (viz., lower for low-income work. ers). MediKids component funded in part through MediWorkers premiums. Additional premiums for 3 MediKids component and premiums for MediWrap com- ponent capped at the percent of income applied under the MediWorkers component. Deductible and Coinsurance.-Throughout the UniMed Program, reduction/rebate of cost-sharing for individuals with income below poverty level, with phase-out in low- income assistance until there is no assistance for those with income exceeding 200 percent of poverty level. February 20, 1992 (12:50 p.m.) UNIVERSAL MEDICAL CARE (UNIMED) ACT OF 1992-Continued Overview/Summary Title/Program Summary of Policy Notes F:\FHBC\UNIMED Title VI. Financing UniMed Program generally keyed to funding based on the MediWorkers National Premium Percentage, as pre- scribed by HBA. MediWorkers Component.-Financed entirely through payroll-related premiums, with employees paying no more than 20%. No Federal funding component. MediKids Component.-Financed for MediWorkers chil- dren entirely through MediWorkers premiums. Financed for MediWrap children through an addition to the MediWrap community-based premiums, "equalized" pay- roll taxes on employees under 22, and State medicaid maintenance of effort payment (with additional Federal revenues). MediWrap Component.-Comnunity-rated premium (subject 4 ome cap), UniMed self-employment taxes, "equalized" payroll taxes on part-time and seasonal em- ployees, and Medicaid maintenance-of-effort payments. Low-Income Assistance.-(1) Income tax on gross in- come (other than wages and self-employment income subject to premium or taxes under MediWorkers, MediKids, or MediWrap components of UniMed) at flat rate (of approx. 1.5%), and (2) other revenue sources. Small employer transitional subsidy.-Other revenue sources. Medicare program expansion.-Increase in cap on HI part of FICA and SECA (adjusted annually) to finance Medicare changes described below (see title VIII). February 20, 1992 (12:50 p.m.) Title VII. Overall Administration Establislunent of independent Health Benefits Adminis- tration (HBA) headed by a 15-member board. HBA controls a Federal Health Benefits Equalization Corporation (FHBEC), with data collection functions and F:\FHBC\UNIMED special function under the MediWorker component relat- ing to "equalizing" premiums paid by employers and "equalizing" premiums received by plans. Additional special provisions with respect to enforce- ment (including an early resolution program to settle grievances andadministrative review procedures). Several specified advisory cominittees, to deal with ben- efits and coverage, rates, etc. Title VIII. Medicare Changes Reduction in age of initial eligibility from 65 to 60, ef- fective January 1, 1995. Title XIX. Miscellaneous Repeal of COBRA Continuation Grants program to expand services of Federally quali- fied health centers. Conforming Medicaid program to earlier changes. 5 February 20, 1992 (12:50 p.m.) UNIVERSAL MEDICAL CARE (UNIMED) ACT OF 1992 Table of Contents of Provisions Title Subtitle Provision F:\FHBC\UNIMED F:\FHBC\ UNIMED TITLE I. MEDIWORKERS COMPONENT OF Subtitle A. Employer Mandate A1. Enrollment Requirement UNIMED A2. Certification of Employer Coverage Under Plan A3. Coverage Based on Employment in Previous Month Subtitle B. Group Health Plan Requirements Summary of Requirements for all Group Health Plans Subtitle C. Required "Core" Benefits C1. Core Services C2. Deductible C3. Coinsurance/Copayments C4. Limit on Cost-Sharing Subtitle D. Maximum Charge Limits and Minimum D1. Establishment of Reference Payment Rates Payment Rates D2. Maximum Charge Limits D3. Minimum Plan Payment Rates D4. Payment Methodologies D5. Controls on Capital Expenditures for Hospitals Subtitle E. Employee and Consumer Protections E1. Limit on Employee Premiums E2. Treatment of Pre-existing Conditions 9 E3. Consumer Protections E4. Standardization and Benefit Portability E5. Additional Requirements for Network Plans Subtitle F. Additional Requirements for Insured Plans F1. Guaranteed Availability F2. Guaranteed Renewability F3. Offering of Minimum Benefit Plan F4. Premiums/Rating F5. Plan Certification for Employers F6. Enforcement of Requirements for Insured Plans Subtitle G. Premium Equalization Process G1. Summary/Overview G2. Specification of Employer Premiums (MediWorkers National Premium Percentage (MNPP)) G3. Requirement of Equalization G4. Computation of Capitation Amounts G5. Information Reporting G6. Transitional Premium Subsidy for Small Business H.L.C. 20, 1992 (12:50 p.m.) Subtitle H. Enforcement and Related Administrative Is- H1. Enforcement of employee's rights under group sues health plans through Special Counsel and Group Health Plan Review Board H2. Additional enforcement actions FHBC\UNIMED H3. Effect of enforcement prevision H4. Miscellaneous enforcement and administrative pro- Visions. Subtitle I. Miscellaneous 11. Preemption of State provisdns 12. Repeal of COBRA Contination Requirements 13. Incruase Deduction for Ixpenses for Self-Employed TITLE 11. MEDIKIDS COMPONENT OF unimed Subtitle A. Eligibility/Entillement Subtitle B. Required Benefits 111. Services 112. Deductible B3. Coinsurance Bd Limit on Cor-Sharing Subtitle C. Payments for Services CI. Phyment Dates 12 Payment Method Subtitle D. Miscellaneous DI. Premiums D2. Use 0 Intermediaries 7 D3. Treitment of HMO's and Capitation 1)4. Reation to Medicare and Medicaid Programs D5. Inforcement TITLE III. MEDIWRAP COMPONENT OF UNIMED Subtitle A. Eligibility/Entitlement Subtitle B. Benefits Subtitle C. Payments for Services C1. Payment Rates C2. Payment Method Subtitle D. Miscellaneous D1. Premiums 1)2. Use of Intermediaries D3. Treatment of HMO's D4. Relation to Medicaid Program D5. Enforcement TITLE IV-COST CONTAINMENT AND QUALITY Subtitle A. Determination of Premiums Based on CONTROL Mediworkers National Premium Percentage (MNPP); Use of Capitation Rates Subtitle B. Payment Levels H.L.C. Subtitle C. Controls on Capital Expenditures UNIVERSAL MEDICAL CARE (UNIMED) ACT OF 1992-Continued Table of Contents of Provisions Subtitle Provision Title IBC\UNIMED Subtitle D. Encouraging Use of "Managed" or "Coordi- D1. Encouraging UBe of "Network Plans" nated" Care D2. Encouraging Use of Utilization Review D3. Use of Practice Guidelines and Outcome Research D4. Quality Control Mechanisms Subtitle E. Improvements in Administrative Efficiency E1. Uniform Claims Forms and Electronic Billing E2. Uniform Health Cards Subtitle F. Medical Malpractice Reform Subtitle G. Cost Contuinment-MediKids and G1. Payment Rates MediWrap Components G2. Encouraging Use of "Managed" or "Coordinated" Care G3. Improvements in Administrative Efficiency G4. Medical Malpractice Reform A. Premum Assistance TITLE V-LOW-INCOME ASSISTANCE B. Deductbles and Coinsurance Assistance 8 C. Applicatnn Process Subtitle A. MediWorkers Component of UniMed A1. Employee Share TITLE VI-FINANCING A2. Treatment otSelf-Employed A3. Treatment of Children and Part-Time and Seasonal Workers A4. Effective Date and Maintenance of Employer Effort A5. Funding Early Rewlution Program and Adminis- trative Review Process A6. Funding Transitional Premium Subsidy for Small Business Subtitle B. MediKids Component of UniMed B1. MediKids Element of MedWorkers National Premi- um Percentage (MNPP) B2. MediKids Element of MediWr.p Premium B3. State Medicaid "Maintenance "Effort" Payment. B4. Treatment of Workers under Age22 B5. Additional Federal Funds. H.L.C. 3 Subtitle C. MediWrap Component of UniMed C1. Actuarial Premium Collected Through Income-Tax System C2. State Medicaid "Maintenance of Effort" Payment F:\FHBC\UNIMED F:\FHBC\ UNIMED C3. MediWrap Employment Equalization Tax for Part- Time and Seasonal Workers C4. MediWrap Tax on Self-Employment Income C5. Source of Additional Federal Funds Subtitle D. Medicare Program Eligibility Expansion Subtitle E. Low-Income Assistance TITLE VII-OVERALL ADMINISTRATION A. Health Benefits Administration (HBA); basic struc- ture B. Federal Health Benefits Equalization Corporation (FHBEC) C. Office of Special Counsel D. Early Resolution Program (ERP) Office E. Group Health Plan Review Board (GHPRB) TITLE VIII-MEDICARE REVISIONS A. Reduction in Age of Medicare Eligibility 6 TITLE IX-MISCELLANEOUS PROVISIONS A. Repeal of COBRA Continuation Requirements B. Grant Program for Expansion of Federally Qualified Health Centers H.L.C. February 20, 1992 (12:50 p.m.) UNIVERSAL MEDICAL CARE (UNIMED) ACT OF 1992 MediWorkers Component of UniMed [title I]-Employer Mandate Issue/Topic Policy Notes F:\FHBC\UNIMED A. EMPLOYER MANDATE [subtitle A of title I (new MediWorkers component of UniMed will be set forth in subtitle A of title V of ERISA)] new title V of ERISA. Title I of ERISA will be amended so as to restrict its ap- plicability with respect to group health plans to the fidu- ciary provisions of part 4 of subtitle B. Reporting re- quirements for group health plans will be part of new title V of ERISA. The enforcement and court review pro- visions of part 5 of subtitle B of title 1 will continue to relate to group health plans, but only with respect to rules contained in part 4 of subtitle B (fiduciary duties). New enforcement provisions in title V of ERISA will re- late to all other aspects of ERISA regulation of group health plans. Necessary amendments will be made to ensure that preemption of State law with regard to matters not COV- ered under title I will be provided in new title V. Pre- 10 emption will be maintained under title V with respect to group health plans in the same manner and extent as currently provided under title I. A1. Enrollment Requirement -All employers are required to enroll full-time employ- ecB (and spouses who are not full-time employees) who are not children under an employee welfare benefit plan (as defined in title I of ERISA) that is a qualified group health plan (us defined below). U.S. companies employ- ing U.S. nationals abroad would have to meet this re- quirement. These plans can be insured or self-insured. Self-em- ployed individuals (with or without employees) would be covered under MediWrap component of UniMed. Coverage would begin with the month following the month in which became a full-time employee (or spouse). Effective Date.-Requirement becomes effective us of January 1, 1995; except not apply to workers (and fumi- ly) receiving any health care coverage under the terms of is current collective bargaining agreement. H.L.C. A2. Certifi of Employer Coverage Under Plan 20, 1992 (12:50 p.m.) A2. (a) Requirement Each employer must provide to the Health Benefits Ad- ministration (HBA) at such times (not less often than annually) as HBA specifies a certification from a quali- fied group health plan of coverage of full-time employees (and related spouses) of the employer under the plan. The plan could charge the employer premium in ad- vance (but not for more than 3 months in advance) to make the certification. The plan would assume the risk of collection for premiums during the period of certifica- tion. A2. (b) Enforcement -IRS shull provide HBA requested information on em- ployer identification numbers issued; these would be matched up against HBA records to find out about em- ployers not reporting. -If employer failed to meet requirement (viz., failed to provide required coverage or certification thereof) after warning from the HBA, the HBA through an order (which is enforceuble in court)- (1) would assign full-time employees (and spouses) to a 11 qualified group health plan, (2) would assess the employer the amount of premium otherwise due, plus 50 percent, (but the employer would be prohibited from charging employees any more) during a 3 month period, and (3) would require the employer to provide information on payroll for employees. An employer's fuilure to pay the premium (and penalty) ussessed would create a lien (which would have priority in bunkruptcy proceedings). A3. Coverage Based on Employment in Previous Group health plan in liable for those employed full-time This would also be used as model for portability under Month during the previous month for that employer [this would, the UniMed program. effectively, require a week's worth of work before you take responsibility]. If an employee left one job and started another job during a month, in the following month the last full-time employer would assume respon- sibility. The group health plan must continue to provide coverage to individuals until they leave employment or establish evidence of other full-time employment. H.L.C. February 20, 1992 (12:50 p.m.) UNIVERSAL MEDICAL CARE (UNIMED) ACT OF 1992 MediWorkers Component of UniMed [title I]-Group Health Plan Requirements Issue/Topic Policy Notes F:\FHBC\UNIMED B. GROUP HEALTH PLAN REQUIREMENTS [sub- title A of title I (new subtitle B of title V of ERISA)] Summary of Requirements for All Group Health To be qualified, a group health plan must meet speci- Plans fied requirements (detailed below): [Part I of new Subtitle B] (1) provide required core benefits (see C1. below]; (2) limits on deductibles, and coinsurance, and a limit on cost-sharing [see C.2-4. below]; (3) consumer protection provisions (including maximum employee premiums, no preexisting condition limits, "portability" of benefits, and solvency protection) [see E. below; provisions may be incorporated by reference from general provisions in title VII]; (4) adequate payment rules (Hee D3. below]; (5) meets plan requirements of § 402 of ERISA, trust re- quirements of § 403 of ERISA [no exceptions], and claims 12 procedures of $503 of ERISA; and (6) provide for equalization of premiums and capitation rates for core benefits, including related information re- porting (in accordance with subsequent subtitle) [see F. below]. H.L.C. UNIVERSAL MEDICAL CARE (UNIMED) ACT OF 1992 MediWorkers Component of UniMed [title I]-Required Benefits Issue/Topic Policy Notes F:\FHBC\UNIMED C. REQUIRED "CORE" BENEFITS [Part Il of new Subtitle B] C1. "Coro" Services: Employers can supplement core benefits. Details on definitions to be filled in by HBA. Plans could offer additional benefits (such as hospice care) if desired (particularly if plans found that addition- al benefits resulted in no increase in total costs). C1. (a) Inpatient hospital services Unlimited; except limited to 45 days of inpatient men- tal health services in any year. C1. (b) Physicians' services Unlimited inpatient and outpatient physicians' services [See title IX for grant program to expand community and community health clinic services (except for limit on health centers.) mental health services, see below). C1. (c) Mental health services Limited to 45 days of inpatient care per year and 20 Would be 40 outpatient visits per year under MediKids outpatient visits per year. Would treat as qualified pro- component 13 viders (for outpatient services) psychologists and clinical social workers. C1. (d) Alcohol and drug abuse treatment services Limited specified dollar value (viz., $5,000) in any 3- year period. HBA to review dollar limit and is authorized to update. HBA to specify who are qualified providers. C1. (e) Pregnancy-Related Services Coverage of prenatal, labor, delivery, and postnatal services, including services of certified registered nurse midwives. H.L.C. February 20, 1992 (12:50 p.m.) UNIVERSAL MEDICAL CARE (UNIMED) ACT OF 1992-Continued MediWorkers Component of UniMed [title I]-Required Benefits Notes F:\FHBC\UNIMED Issue/Topic Policy C1. (f) Preventive Services Coverage of-- Screening mammography and screening pap smears (at frequency to be specified by HBA), Family planning services, & Adult immunizations. HBA to establish an advisory committee (which would include doctors and repre. of employers, employees, and employer health plans) to make recommendations on ad- ditional preventive benefits. HBA can add new preven- tive benefits (for all or for populations at risk) if appro- priate, taking into account cost, but only after providing at least 2 years' notice (so Congress has time to respond and 80 employers and plans can adjust to the new bene- fits). C1. (g) Laboratory and Diagnostic tests Diagnostic and laboratory tests are covered. 14 C1. (h) Case management services To be covered for people diagnosed with certain ail- ments, specified by HBA. HBA to provide minimum stundards of qualifications for case managers. C1. (i) Determinations of Covered Services Benefits are required only for medically necessary and reasonable services, or, in the case of preventive services, in accordance with periodicity schedules. HBA would establish an advisory committee for review- ing medical necessity. In particular, the Committee would review determinations with respect to experimen- tal treatments. C1. (j). Demonstrations of New Benefits The HBA may provide for a set aside, through the Fed- eral Health Benefits Equalization Corporation (FHBEC) in an amount not to exceed Yiuth of 1 percent of total MNPP premiums, in order to conduct demonstration projects for new benefits and for central funding of ex- perimental treatments (which individual plans are not required to pay for). C2. Deductible Single, per person annual deductible. No "fumily" deductible. H.L.C. February 20, 1992 (12:50 p.m.) C2. (a) Amount $250, indexed by inflation-related increases in SSA wage base (viz., § 230 contribution and benefit base). C2. (b) Exceptions Does not apply to pregnancy-related services or preven- F:\FHBC\UNIMED tive services C3. Coinsurance/Copayments - C3. (a) Percentage 20 percent. C3. (b) Exceptions Does not apply to pregnancy-related services or preven- tive services. Can be greater in the case of provision of services by nonparticipating providers under qualified network plans. C4. Limit on Cost-Sharing $2,500 per person. Amount indexed by increases in SSA Same index as for deductible. "Family" limit is sum of wage base. limits for family members. 15 H.L.C. February 20, 1992 (12:50 p.m.) UNIVERSAL MEDICAL CARE (UNIMED) ACT OF 1992 MediWorkers Component of UniMed [title I]-Payment Rates & Consumer Protection Issue/Topic Policy Notes F:\FHBC\UNIMED D. MAXIMUM CHARGE LIMITS AND MINIMUM PAYMENT RATES [Part III of new Subtitle B) D1. Establishment of Reference Payment Rates In connection with the periodic establishment of the MediWorkers national premium percentage (MNPP) and using medicare payment methodology or similar prospec- tively determined payment methodology, HBA will set reference payment rules. HBA may, upon application by a State, permit substitu- tion of State-based rules, if (1) the rules will apply to all payors (including the MediKids and MediWrap compo- nents), (2) the rates will not result in total expenditures greater than those otherwise permitted under all the programs, and (3) will not result in a significant shifting of costs among the different components. 16 D2. Maximum Charge Limits Institutional services.-For institutional services (viz., Maximum charge limits consistent with medicare other than professional services), the reference payment model. rates are the maximum charges that can be imposed by providers for covered services for individuals under qualified group health plans. Professional services.-For physician and other profes- sional services, the maximum charges are the same pro- portion above the reference payment rates as the limit- ing charge permitted under the medicare RB-RVS pay- ment system. Enforcement.-Violation'of the charge limits would sub- ject providers to civil money penalties and exclusion under MediKids and MediWrap components of UniMed. H.L.C. February 20, 1992 (12:50 p.m.) D3. Minimum Plan Payment Rates QGHPs must provide payment either of at least 95 per- cent of the reference payment rates or establish to the satisfaction of HBA that the rates provide for access to all required benefits without beneficiaries incurring ad- F:\FHBC\UNIMED ditional out-of-pocket expenses. To avoid cost-shifting for direct medical education ex- penses, HBA may require that payment for hospital services for a teaching hospital include an appropriate additional percentage which reflects, in the aggregate, an appropriate percentage to provide for direct medical education costs. HBA will monitor impact of payment rates on capital expenditures and medical education, particularly for dis- proportionate share hospitals. D4. Payment Methodologies Plans must make payment using medicare payment methodologies (e.g., DRG-based system for inpatient hos- pital services, RB-RVS for physician services, etc.). Pay- ment for hospital services would include, as under medi- care, payment for couls of capital and indirect medical education. 17 H.L.C. 112.50 3 February 1992 , 3 - UNIVERSAL MEDICAL CARE (UNIMED) ACT OF 1992-Continued MediWorkers Component of UniMed [title I]-Payment Rates & Consumer Protection Issue/Topic Policy Notes F:\FHBC\ F:\FHBC\UNIMED UNIMED D5. Controls on Capital Expenditures for Hospi- -Hospitals required to report annually to HBA on ex- tals penditures for capital. -HBA will require justification for rates of increase in capital costs identified as excessive. In identifying rates of increase that are excessive, HBA will take into account— 1. allowable rates of increase in maximum charge limits for hospital services (viz., general rate of increase in pay- ments for hospital services); 2. average rate of increase in capital expenditures for hospital services generally; 3. rule of increases in unit costs of capital (e.g., based on an index of costs of construction); and 4. percentage of the hospital's budget devoted to capital expenditures (in comparison with the average hospital) (viz., 80 that hospitals with historically low capital ex- 18 penditures are permitted to rise to the average). -HBA would establish standards (like those used under certificate of need luws) for finding that a higher rate of increase in hospital capital expenditures is justi- fied. In order to provide for predicability, HBA will pro- vide a process under which a hospital could apply, before making capital expenditures that otherwise might result in an excessive rute of increase in capital expenditures, for "pre-approval" of the additional expenditures. -The HBA will reduce, prospectively, the maximum charge limits for hospital services to the extent the iden- tified excessive rate of increase in capital expenditures has not been justified. This is an effective "disallowance" of excessive, unjustified capital expenditures. E. EMPLOYEE & CONSUMER PROTECTIONS [Part IV of new Subtitle B] H.L.C. February 20, 1992 (12:50 p.m.) E1. Limit on Employee Premiums Employee premiums cannot exceed 20% of Employer can pay employee's share, and remains tax- MediWorkers National Premium Percentage (MNPP) es- free to employee. tablished by HBA. F:\FHBC\UNIMED E2. Treatment of Pre-Existing Conditions There may be no preexisting condition restrictions for basic benefits. E3. Consumer Protections -Physician incentive plans (viz., plans that provide di- rect incentives for physicians to reduce or limit services to individuals) must meet medicare requirements. -Insured plans must have satisfuctory protection of en- rollees with respect to potential insolvency and self-in- sured plans must maintain an adequate escrow reserve. -In case of plan insolvency, enrollees will not be liable to providers for more than cost-sharing which would have been required in the absence of insolvency. HBA to establish the solvency standards taking into account those standards required by OPM of plans under the Federal Employees Health Benefits Program (FEHBP). E4. Standardization and Benefit Portability Plans would issue health plan cards in a standard form. 19 Plans would process claims using standard forms and processes established by HBA. In order to assure the continuity and "portability" of benefits and providing additional protection against "job- lock", QGHPs would have to provide notice to the HBA of individuals enrolled and disenrolled under plans and coordinate (in accordance with HBA standards) the ac- counting, reporting, and crediting of deductibles and cost-sharing previously incurred. E5. Additional Requirements for Network Plans Network plans (viz., plans with provider restrictions or [viz., HMOs, PPOs] additional cost-sharing for nonparticipating providers be- yond 20 percent) must meet additional requirements re- lating lo -full disclosure of conditions, & -providing for out-of-plan coverage in cases of emer- gencies. H.L.C. February 20, 1992 (12:50 p.m.) UNIVERSAL MEDICAL CARE (UNIMED) ACT OF 1992 MediWorkers Component of UniMed [title I]-Insurance Reform Issue/Topic Policy Notes F:\FHBC\UNIMED F. ADDITIONAL REQUIREMENTS FOR INSURED Also, insured plans must also meet the following re- These effectively are the elements of 'insurance reform' PLANS quirements: included in the proposal. [Part V of new Subtitle B] F1. Guaranteed Availability Guaranteed availability of busic benefit package for all employers (without regard to size) in any State in which the insurer does business; except that HMO's and simi- lar limited enrollment plans can limit enrollment on a 1st-come-1st served busis and may limit to those employ- ers in their service delivery area (which area must be reasonable, as determined by the HBA). The insurer must agree to take employers assigned to the plan by HBA under A2. above. The HBA would es- tablish a method for reassignment and would pay over to plan 100 percent of premium otherwise due. If HBA believes that reinsurance was not generally 20 available to help small insurers who might otherwise be at risk (because they can no longer underwrite and must depend upon capitation-related income) and that such re- insurance is necessary to carry out the MediWorkers component of UniMed, the HBA is authorized to estab- lish a reinsurance program (and to charge appropriate premiums for this purpose). F2. Guaranteed Renewability Policies must be guaranteed renewable (viz., no cancel- lation by insurer due to health status), unless terminat- ed for cause or unless terminates all group health plans in a State (and, in such сиве, makes financial provision for claims previously incurred). F3. Offering of Minimum Benefit Plan Must offer qualified group health plans that are only States cannot require offering of other benefits or other basic plans (viz., no additional benefits beyond the mini- types of plans; see H1. below. mum), if offer other plans. H.L.C. February 20, 1992 (12:50 p.m.) F4. Premiums/Rating Cannot charge (for basic plans) more than the Risk for insurers will be adjusted through "equaliza- MediWorkers National Premium Percentage (MNPP) tion" process. specified by the HBA. However, there are no price controls on supplemental Plans may not require employers to pay for more than F:\FHBC\UNTMED plans; for such plans insurers can underwrite groups and 3 months of premium in advance. charge unequal premiums for additional benefits. F5. Plan Certification for Employers Will provide for certification to HBA of employers en- rolled under plan. F6. Enforcement of Requirements for Insured Plans Noncomplying insurer subject to administrative en- forcement, including administrative order of specific per- formance plus a penalty of up to $1,000 for each employ- er for each day of noncompliance or, in egregious caBeB, loss of status as a qualified health plan. 21 H.L.C. February 20, 1992 (12:50 p.m.) UNIVERSAL MEDICAL CARE (UNIMED) ACT OF 1992 MediWorkers Component of UniMed [title I]-Premium Equalization Process Issue/Topic Policy Notes F:\FHBC\UNIMED G. PREMIUM EQUALIZATION PROCESS [Subtitle A of Title I (new subtitle C of title V of ERISA)] G1. Summary/Overview G1. (a) Principles of System -(1) Employers effectively pay premiums based on a percent of payroll. [This provides inter-employer equity.] (2) Group health plans, after "equalization", effective- ly receive a netted "actuarial" premium based on the de- mographic characteristics of individuals enrolled. [This provides inter-insurer equity and provides opportunity (and therefore incentive) for health plans to contain costs.] Since health plans are not paid based on actual cost, employees, employers, and plans may "profit" from holding down utilization (either through managed or co- ordinated care or preferred provider arrangements or through employer/employee wellness programs, or other 22 means). G1. (b) Approach to Enforcement of Principles The system will guard against 2 financial risks for group health plans: (1) Plans must collect payroll-based premiums (par- ticularly in the case of employers that go bankrupt in a month) in an effective manner. This is to be accom- plished through plans being permitted to charge premi- ums for months in advance. To provide for predictability, the premium for a month is related to the payroll of cov- ered employees for the previous month. (2) Plans must provide for payment for health benefits accrued during periods of coverage. This would be as- sured through requiring, of all qualified group health plans, adequate protection against insolvency or, in the case of self-insured plans, some type of escrow account or other means found satisfactory by HBA. G2. Specification of Employer Premiums (MediWorkers National Premium Percentage H.L.C. (MNPP)) arv 20. 1992 (12:50 p.m.) G2. (a) In genera. Employers (other than those that are eeting mandate through self-insurance), pay a premium for basic benefits equal to a percenlage (periodically adjusted by HBA) of payroll to the qualified plan. This percentage is referred FHBC\ UNIMED to as the MediWorkers National Premium Percentage or "MNPP". Plans of self-insured employers are treated the same as insured plans for purposes of "equalization" of payable premiums to benefits to be provided. Payroll subject to MNPP would be capped for each worker at twice the maximum wages subject to the So- cial Security tax. G2. (b) Computation of MediWorkers National Premium Percentage (MNPP) G2. (b)(1) In general -Establishment of initial MNPP. The MediWorkers Na- The MNPP specified for the first year will be sufficient tional Premium Percentage (MNPP) of payroll for the 1st to fund the entire MediWorkers component (not includ- year only (viz., 1995) will be specified in the statute. ing any low-income assistance under title V). Subsequent MNPP.HBA will adjust the MNPP each For timing and process (including use of advisory com- year to reflect changes in health care costs relative to mittees), see below. 23 payroll. HBA must set the MNPP high enough to cover all expenses. HBA can provide for a contingency margin and can set up as reserve (to stabilize rates during reces- sionary times or for epidemics). The HBA would adjust the MNPP each year based on errors in projections of utilization and total wages in pre- vious years. G2. (b)(2) Determination of Trend in Health Care Costs Health care costs (including administrative costs) to be (Numerator) for MNPP and In Determining Reference trended (based on costs in 1991), taking into account the Payment Rates following: H.L.C. February 20, 1992 (12:50 p.m.) UNIVERSAL MEDICAL CARE (UNIMED) ACT OF 1992-Continued MediWorkers Component of UniMed [title I]-Premium Equalization Process Issue/Topic Policy Notes F:\FHBC\UNIMED UNIMED (A) Unit health care costs inflation factor (e.g., reflect- In determining appropriate unit cost inflation, the HBA ing update in conversion factor for physician services or would have to consider the 2 different factors which change in marketbasket for hospital services) must be reconciled: (1) increases in wages per covered in- dividual [which is the increase in the revenue stream for the MediWorkers component] and (ii) increases in inputs which drive costs of providing services (namely, the types of factors used in medicare "marketbasket". -type in- creases). The unit health care inflation factor derived in this process would be used by HBA in determining the refer- ence payment rules for employer plans (and in establish- ing payment rates under MediKids and MediWrap com- ponents of UniMed). The HBA would establish an advisory committee on health care unit costs. 24 (B) Changes from Medical Care Improvements This would include new procedures, as well as devices and new benefits (including preventive benefits). This would take into account efficiencies resulting from medi- cal care innovations. The HBA would use the technology advisory committee (established for purposes of making coverage recommen- dations on experimental procedures) for purposes of re- viewing this component. H.L.C. February 20, 1992 (12:50 p.m.) (C) Trends in demographics and utilization This would take into account changes in number of cov- ered individuals and changes in "ge composition in COV- ered individuals, as well as any changes in required ben- efits under the MediWorkers component of UniMed. F:\FHBC\UNIMED UNIMED Also, HBA would evaluate efficiencies which have re- sulted or could result from applications of practice guide- lines and any evidence of inappropriate utilization of services, as well as evidence of lack of access to or use of necessary services. This factor would also take into ac- count the use of health maintenance organization and other incentives towards managed or coordinated care. HBA obtains from FHBEC data on utilization of differ- ent services during the past (to detect trends). The HBA would establish a separate advisory commit- tee to review these demographic and utilization changes. In addition, the views of the advisory committee on qual- ity would be tuken into account in the review of utiliza- tion. (D) Changes in Administrative Costs This reflects administrative costs as a relative percent of other expenditures. This would take into account costs 25 for administration of medicare program and coets for ad- ministration of private health plans. This would also take into account any need to implement data collection systems und utilization/peer review systems, and any new administrative mandates established by HBA. It would assume implementation of electronic billing ByH- teins (in conjunction with uniform claims). (E) Changes in Contingency margin/reserve This is optional and could serve to buffer percentage fluctuations from year to year in the economy as well as to help buffer cash flow fluctuations. (F) Adjustment for previous year over/under estimates. In outyears, an adjustment factor to compensate for over and under-estimations on utilization and other fac- tors from those assumed. (G) Change in Demonstration Allowance This would reflect any change in the optional demon- stration allowance (not to exceed Y₁₀ of 1 percent). H.L.C. February 20, 1992 (12:50 p.m.) UNIVERSAL MEDICAL CARE (UNIMED) ACT OF 1992-Continued MediWorkers Component of UniMed [title I]-Premium Equalization Process Issue/Topic Policy Notes F:\FHBC\UNIMED UNIMED G2. (c) Projection of Wages (Denominator) (1) HBA would determine projected total wages subject to the MediWorkers premium calculation during the sub- sequent year. The Federal Health Benefits Equalization Corporation would provide data on structural changes in workforce (e.g., shift from manufacturing to service) and other useful historical duta. Like the Social Security Boards of Trustees, the HBA would make 3 projections: optimistic, neutral, and pessi- mistic. The HBA could provide for a contingency reserve for wage shortfalls to deal with possibility of economic downturn (to prevent the need to cut benefits or to pro- vide for massive changes in the MNPP during reces- sions); this would be achieved by assuring full funding under the most pessimistic assumptions. The middle would be used to make the computation, but there would have to be a sufficient reserve to assure funding if the 26 most pessimistic assumption were to come true. The HBA would establish a wage advisory committee to review G2. (d) Process The MNPP to be established annually by HBA by regu- lation. MNPP (and additional information, such as pay- ment rates) for a year to be published in proposed form by August 1 of previous year, with a 60 day comment pe- riod; final regulation to be published by November 15 of that previous year. Process will begin in 1994 for 1/1/95 effective date. H.L.C February 20, 1992 (12:50 p.m.) G2. (e). Computation of Employer Premium Employer premiums for a month would be total payroll This principle reflects coverage under plan based on (for full-time, 08 well as part-time and children) employ- employment during previous month. The lag permits the eeB during the previous month. system to use more accurate data and provide for greater In order to "capture" wages for employers going out of F:\FHBC\UNIMED ::\FHBC\ predictability and stability. business, in group health plans equalizing premiums with capitation with FHBEC, the group health plan is assumed, with respect to an employer, to have collected the same amount for a month as the amount for the pre- vious month; this would be to take into account employ- ers that go out of business and don't provide information on wages for the month in which they go out of business. G2. (f) Collection of Employer Premiums Generally, the timing of collection of premiums is left up to negotiation between employers and plans. However (in order to deal with problems of small employers)- (1) a qualified plan cannot require payment for more than 3 months of premiums; (2) in estimaling amount of premiums, the plan cannot base estimated premiums for future periods on amounts exceeding the MNPP of the most recent actual payroll; and 27 (3) the plan must provide for adjustment, not less often than quarterly, of any estimated premiums based on actual payroll. H.L.C. February 20, 1992 (12:50 p.m.) UNIVERSAL MEDICAL CARE (UNIMED) ACT OF 1992-Continued MediWorkers Component of UniMed [title I]-Premium Equalization Process Issue/Topic Policy Notes F:\FHBC\UNIMED G3. Requirement of Equalization -Equalization Premiums Payable to FHBEC.-Each qualified group health plan (including self-insured emi- ployers and Taft-Hartley plans) must pay to the Federal Health Benefits Equalization Corporation (FHBEC, which is within the Health Benefits Administration) an amount equal to the amount by which (A) the employer premiums (viz., computed as an HBA-specified percent of payroll) exceed (B) the "capitation amount" [Bee G4 below] for all individuals covered under the plan. Equalization Rebates Paid by FHBEC-FHBEC must pay each group health plan (including self-insured em- ployers and Tuft-Hartley plans) an amount equal to the amount by which (A) the employer premiums (viz., per- cent of payroll) [see G3 below] are less than (B) the "capi- tation amount" [see G4 below) for all individuals covered under the plan. 28 Payments and rebates would be made, not less often than quarterly, accordingly to schedule established by FHBEC. G4. Computation of Capitation Amounts G4. (a) Summary The capitation amount, which is used by FHBEC as a reference rate for the amount employer plans should have received for basic benefits, for an individual is equal to the product of a buse rute (common to all indi- viduals) and the weighting factors (for the actuarial class to which the individual is assigned). The base rate and weighting factors (as well as actuarial classes) are estab- lished by the HBA under the process described below. H.L.C. February 20. 1992 (12:50 p.m.) G4. (b) Establishment of Actuarial Classes The HBA shall assign individuals covered under quali- fied group health plans to "actuarial classes". These classes are established by the HBA, based on a combina- tion of age, sex, disability status, area of residence, and F:\FHBC\UNIMED other appropriate factors, and would be actuarially sound. The HBA shall establish the minimum number of actuarial classes and shall not provide for disease-specif- ic or condition-specific classifications. Within each class, insurers can reasonably anticipate that individuals will use similar amounts of basic health benefits. G4. (c) Computation of Relative Weight for Each Actuar- Using sample data supplied by FHBEC in its work, the ial Class HBA computes "weighting factors" that reflect the rela- tive costs of each actuarial class compared to the average for all the classes. So a weight of "1.0" represents an av- erage risk or average amount of anticipated health care expenditures. A weight of "2.0" represents as group that is likely to have health cure expenses for busic services that are twice the national average. The weights would be subject to annual adjustment. 29 FHBEC would obtain information, on covered individ- uals by social security number only, on plan enrollment, age, sex, and other relevant actuarial characteristics nec- essary to assign accurate weighting factors for each indi- vidual. Privacy Act protections would apply to restrict use and disclosure of the information. There would be a one-time collection of information; information would be periodically audited (in conjunction, say, with the audit- ing of how much spent for different classes of individ- uals) and individuals would have acceBB to verify or change information. The information would only be used for purposes of capitation payment computations. Quali- fied group health plans would be required to report to FHBEC information on "medical events affecting capita- tion" [things that would affect, prospectively, payments to be made to plans], by social security number only. In the equalization process, QGHPs would submit the social security number of covered individuals and would receive payment for all individuals on on aggregate (viz., there would be 110 individual specific payment). H.L.C. February 20, 1992 (12:50 p.m.) UNIVERSAL MEDICAL CARE (UNIMED) ACT OF 1992-Continued MediWorkers Component of UniMed [title I]-Premium Equalization Process Issue/Topic Policy Notes F:\FHBC\UNIMED G4. (d) Computation of National Average Expenditures The FHBEC would compute each year, based on the (Base Rate) MediWorkers national payroll percentage (MNPP), a na- tional average per capita amount of expenditures ("base rate") for basic health care services under all qualified group health plans (including self-insured plans). This base rate would be based on formula: (A) total projected payroll for MediWorkers covered individuals subject to MediWorkers premiums, times (B) MNPP, divided by (C) average number of covered individuals under MediWorkers component of UniMed. The base rale would not take into account discounting from the payment rates. The HBA may ask the FHBEC to examine historical in- formation on utilization to recommend appropriate weighting factors to be applied. 30 G4. (e) Computation of Capitation Amount For each individual in an actuarial cluss, the "capita- tion amount" would be the product of the national aver- age expenditures and the weighting factor for the class. G5. Information Reporting Qualified group health plan must report quarterly to the FHBEC information on (1) case (viz., demographic/ actuarial) characteristics of enrollees, including informa- tion on "medical events affecting weighting factors" and (2) payroll for covered enrollees. Qualified group health plans must report to GAO and Information to be used (1) to check appropriateness of FHBEC (and HBA) information (not in individually iden- the MediWorkers National Premium Percentage (MNPP) tifiable form) required to audit expenditures for core ben- and the capitation amounts are appropriate and (2) to efits. identify patterns of under-utilization. H.L.C. G6. Transitional Premium Subsidy for Small Busi- Businesses with 25 or fewer employees would be eligi- Taking into account the subsidy, for small employers, ness ble for a subsidy to reduce the employer share of the employer share of the premiums would increase from MediWorker premiums. 40% to 80% of the MNPP. F:\FHBC\UNIMED The subsidy would begin at 50% of the employer share in 1995, and be phased down to be 37.5%, 25%, & 12.5% in 1996, 1997, & 1998. Employers would apply to the HBA for the subsidy. The subsidy would be available as a direct reduction of the premium required of the employer (and charged by an insurer against the employer). 31 H.L.C. February 20, 1992 (12:50 p.m.) UNIVERSAL MEDICAL CARE (UNIMED) ACT OF 1992 MediWorkers Component of UniMed [Title I]-Enforcement and Related Administrative Issues Issue/Topic Policy Notes F:\FHBC\UNIMED H. ENFORCEMENT AND RELATED ADMINISTRA- TIVE ISSUES [subtitle A of title I (new subtitle D of title V of ERISA)] H1. Enforcement of employee's rights under group health plans through Special Counsel and Group Health Plan Review Board H1. (a) In general -After exhausting plan's own claims review procedures (see H4. (a) below), employees may bring complaints to Special Counsel of HBA, who will attempt to resolve dis- putes in Early Resolution Program (ERP). -Special Counsel or employee may bring disputes left unresolved by ERP to administrative review before AIJ of the Group Health Plan Review Board (GHPRB), sub- ject to court review in Federal Circuit Court of Appeals of appropriate Circuit. 32 H1. (b) Special Counsel process -Exclusive avenue for actions against group health plans is by means of complaint filed with local office of Special Counsel (SC) -Complaint must be brought within 1 year after notifi- cation of plan. -Complainant informs SC of desire to use ERP at time of complaint. -Within 10 days, SC notifies plan of complaint and of election (if any) of complainant for ERP. -If ERP is not elected, SC decides within 75 days after date of complaint whether the SC has reasonable cause to bring the complaint as a charge before an AIJ of the GHPRB. -If ERP is not elected, upon the earlier of 75 days or finding of no reasonable cause, SC must issue right to proceed letter to complainant. Upon receipt of right to proceed letter, complainant may bring charge to an AIJ of the GHPRB independently of the SC. H.L.C. February 20, 1992 (12:50 p.m.) H1. (c)(1) Early Resolution Program -Plan must submit to ERP upon election by complain- ant. Process runs for 120 days after notification of plan by SC. Otherwise applicable administrative review proc- ess is held in abeyance during ERP. F:\FHBC\UNIMED -1. A Director of the ERP and staff will develop pro- gram procedures, conduct case intake, maintain roster of "facilitators", coordinate fucilitator selection process, pro- vide meeting sites, maintain records, and provide facilitators with legal assistance and administrative sup- port staff. -2. HBA Board administers program through the Di- rector of the ERP. In acting as administrator of ERP, Board will include 2 additional experts in mediation and reconciliation of disputes, one representing plan interests and one representing employee interests. 3. Board will establish lawyer referral panels, legal specialty panels, and health benefits consultants panel to serve as resources for assistance to facilitators and the parties involved in ERP. H1. (c)(2) Requirements for referral to ERP -1. Dispute involves participant's assertion of 33 -(A) claim for health benefits (which may be accompa- nied by claims such as age discrimination, unjust termi- nation, etc.); -(B) plan's failure or refusal to comply with partici- pant's request for information or documents; or -(C) plan's failure otherwise to comply with require- ments of applicable law. -2. Plan has issued final determination under plan's claim procedure under same standards required under $503 (picked up in title V) and participant elects to par- ticipate in process. 3. All parties have opportunity to obtain independent legal advice to determine whether to enter process, ob- tain legal representation, basic legal and factual issues involved. H.L.C. February 20. 1992 (12:50 0 m.) UNIVERSAL MEDICAL CARE (UNIMED) ACT OF 1992-Continued MediWorkers Component of UniMed [Title I]-Enforcement and Related Administrative Issues Issue/Topic Policy Notes F:\FHBC\UNIMED UNIMED H1. (c)(3) Certain parties excluded. -Certain coBeB excluded— -(A) case in which complainant is unable to have a basic understanding of the ERP process, unless they are represented by a legal guardian or other court-appointed representative; -(B) matters within 90 days of court filing dates under limitation statutes. H1. (c)(4) Role of facilitators -Facilitators in the process will do the following: -1. Facilitate discussions between parties to assist them in: -(a) eliminating simple misunderstandings and dis- putes arising from ill feelings or lack of communication, -b) gaining a better understanding of opponent's posi- tion, -(c) identifying settlement options and undisputed is- 34 sues. -2. Clarify legal and factual issues involved. 3. Identify additional key information and documents for assessing parties' positions and predicting outcome of further adjudication. 4. Encourage settlement by suggesting areas of con- sensus. 5. Assist in drafting of settlement agreements. -6. Present the parties with assessment of respective positions and likely outcome of further adjudication. H.L.C. February 20, 1992 (12:50 p.m.) H1. (c)(5) Entry into ERP proceedings Neither party waives right to further adjudication of is- sues at conclusion of process. -1. Plan must inform participants of ERP when re- F:\FHBC\UNIMED sponding to benefit cluims. -2. SC will encourage referrals by organizations and agencies. -3. SC presents participants with written description of program and requests signed contract to participate under rules. Contract forwarded to plan for signature. $100 filing fees filed by both sides (with waiver authority for participants) H1. (c)(6) Selection, impartiality, assignment of 1. Facilitators recruited by Board from among qualified facilitators professionals who have demonstrated- -(a) expertise in the law governing employee benefits, -(b) health plan experience -(c) ability to act impartially, -(d) ability to perform quick evaluations and to present them in nontechnical terms, and -(e) ability to foster communication between parties and encourage settlement in an informal setting. 35 -2. To ensure impartiality, the Board shall- -(a) require disclosure upon application for position of facilitator situations where conflicts of interest might be anticipated, -(b) assess impartiality during training by Board, -(c) request facilitator to identify any possible conflict at time of case assignment, -(d) ask evaluation by parlies. 3. Facilitators will be assigned on blind, random basis, with opportunity on both sides to strike unaccept- able selections. H.L.C. February 20, 1992 (12:50 p.m.) UNIVERSAL MEDICAL CARE (UNIMED) ACT OF 1992-Continued MediWorkers Component of UniMed [Title I]-Enforcement and Related Administrative Issues Issue/Topic Policy Notes F:\FHBC\UNIMED F:\FHBC\ UNIMED H1. (c)(7) 120-day process-Timetable -1. Plan notified within 10 days of complainanťs elec- tion to enter program. -2. Facilitator selected within 30 days after notifica- tion of plan 3. Analysis stage lasts 45 days 4: Evaluation stage lasts until end of 120-day period following notification of plan -5. Process may be suspended to permit agency ruling or to permit second conference upon consent of complain- ant and plan. 36 H.L.C. UNIVERSAL MEDICAL CARE (UN ED) ACT OF 1992 MediWorkers Component of UniMed [Title I]-Enforcement and Related Administrative Issues Issue/Topic Policy Notes \FHBC\UNIMED \FHBC\ UNIMED H1. (c)(8) 120-day process-Analysis Stage -1. IN GENERAL.-In the commencement of the confer- ence proceedings of the Early Resolution Program with respect to any dispute, the facilitator assigned to the dis- pute shall- -(A) identify the necessary parties, (B) confirm that the case is eligible for the Program, -(C) ensure that the requirements of (c)(2) and (c)(3) are met and that each party is informed that, while legal representation is not necessary, there is legal represen- tation available, (D) set a conference date, -(E) at the option of the fucilitator, request position papers from the parties of not more than 10 pages in length, if the facilitator determines that such papers are needed to clarify the parties' positions and issues in dis- 37 pute, -(F) with appropriate legal assistance provided by the SC, analyze the record of the claims procedure conducted pursuant to plan's internal claims review procedure and any position papers submitted by the parties to deter- mine if further case development is needed to clarify the legal and foctual issues in dispute, and whether there is any need for additional information and documents. H.L.C. UNIVERSAL MEDICAL CARE (UNIMED) ACT OF 1992-Continued MediWorkers Component of UniMed [Title I]-Enforcement and Related Administrative Issues Issue/Topic Policy Notes F:\FHBC\UNIMED -2. POSITION PAPER REQUIREMENTS.-Any position paper referred to in paragraph (1)(E) which is submitted by a party shall include a brief, informal statement of the facts, the issues, and the arguments in support of the party's position, together with any additional infor- mation or documents which the parly would like to have considered. The parties may attach to such papers any relevant documents or other evidence. Copies of each po- sition puper will be sent to the other party. -3. FURTHER CASE DEVELOPMENT.-Further case devel- opment pursuant to paragraph (1)(F) shall be accom- plished by directing parties to clarify legal issues and to produce additional information and documents, identify- ing the need for any agency rulings, consulting with ex- perts, and conducting brief legal research as needed. 38 4. COORDINATION OF COMMUNICATIONS.-Any commu- nications with the purties pursuant to this subsection shall be made through letters addressed to both parties or conference calls. Copies of any correspondence to or from a party will be provided to the other. H.L.C. H1. (c)(9) 120-Day Process-Evaluation stage -EVALUATION STAGE.-Conference proceeds us follows: -1. The facilitator convenes conference between the parties, designed to last between 2 and 4 hours. -2. At the outset of the conference, the facilitator reit- F:\FHBC\UNIMED erates objectives and groundrules. 3. The facilitator asks each party additional questions as determined necessary by the facilitator. If written po- sition papers were not required by the facilitator, each party shall be given the opportunity to make a state- ment summarizing the facts, issues, and arguments in support of such purty's position, and present, or inform the fucilitator of, any additional evidence such party con- siders to be relevant to the evaluation. -4. The facilitator maintains neutral stunce between the parties. 5. The facilitator encourages parties to discuss posi- tions openly, with the goal of identifying undisputed is. sues and exploring settlement. -6. If settlement is reached, facilitator assists in the preparation of " written settlement agreement (which shall remain confidential at the option of the parties) 39 and shall explain the terms of the settlement to parties. -7. If no settlement is reached, the facilitator presents evaluation, including an assessment of the parties' posi- tions and the likely outcome of litigation. The evaluation may also include suggestions for narrowing the issues in dispute (through agency rulings, additional discovery, or other means). 8. The facilitator encourages parties to discuss settle- ment again, or to enter into partial agreement on as many issues as possible. -9. A second conference may be scheduled at the sug- gestion of the fucilitator or a party if it is likely to lead to settlement or a substantial narrowing of the issues. -10. The facilitator not to meet separately with either purty. All parties are present at any conferences held during the proceedings. H.L.C. UNIVERSAL MEDICAL CARE (UNIMED) ACT OF 1992-Continued MediWorkers Component of UniMed [Title I]-Enforcement and Related Administrative Issues Issue/Topic Policy Notes F:\FHBC\UNIMED H1. (c)(10) 120-day proceeding-expert assistance to -1. INDEPENDENT PROFESSIONALS.-The facilitator facilitutor may, with respect to any dispute to which the facilitator is assigned, appoint not more than 2 independent profes- sionals to assist in mediation and conciliation on issues with respect to which such professionals have special ex- pertise. -2. Legal AND ADMINISTRATIVE support.-Each facilitator may be assisted by one or more Employee Benefit Specialists assigned by the Board, consisting of an attorneys employed in the HBA specializing in benefit issues under this Act. 40 H.L.C. February 20, 1992 (12:50 p.m.) H1. (c)(11) ERP-Misc. -1. Facilitators compensated on hourly basis and re- -Costs.-No additional fees on complainants. Annual ceive travel and out-of-pocket reimbursement. Allowed to user fee on plans at $.05 a head (with special rules for serve pro bono. smaller plans). Costs of ERP to be covered by $100 entry -2. Facilitators shielded from liability to parties. F:\FHBC\UNIMED UNIMED 3. Parties may be represented. Board will ensure that parties are referred to experienced lawyers with exper- tise. -4. Legal Effect.-Facilitator may assist in drawing up binding settlement agreement between parties. Procedings completely non-binding if no settlement is reached. If settlement is reached, non-binding and non- precedential with respect to those not party to the pro- ceedings. Settlement agreements are filed in Federal dis- trict court and enforceable by the court upon application of any party. Neither party to waive rights as part of agreement. Parties may withdraw at any time before set- tlement. -5. Procedural rules.-No formal rules of evidence. All statements and evidence admissible. Ouths not required for submission of evidence. -6. Confidentiality.-Oral and written communications 41 generated within the contest of ERP not subject to dis- covery in any subsequent legal proceeding, except -(a) the settlement agreement itself (if any), -(b) facilitator's final case report indicating no settle- ment reached. Parties may agree in settlement to provide for confiden- tiality of settlement. No transcripts or recordings made. Facilitator's evaluation is oral. Outside expert's testimo- ny oral. H1. (d) Review by Group Health Plan Review Board -SC, or complainant with right to proceed letter from (GHPRB) SC, appeals to GHPRB if matter not resolved in ERP. H1. (d)(1) Hearings, etc Every official act of GHPRB entered of record, hearings subject to §554 of APA, and hearings and records open to public. May muke rules for proceedings, but unless other rule adopted, Federal Rules of Civil Procedure apply. H.L.C. February 20, 1992 (12:50 p.m.) UNIVERSAL MEDICAL CARE (UNIMED) ACT OF 1992-Continued MediWorkers Component of UniMed [Title I]-Enforcement and Related Administrative Issues Issue/Topic Policy Notes F:\FHBC\UNIMED H1. (d)(2) Depositions, evidence, fees GHBRB may order testimony by deposition. Persons may be compelled to appear and depose, produce evi- dence. H1. (d)(3) Investigatory powers Same powers as NLRB H1. (d)(4) ALJ determinations; final order of Board An ALJ appointed by Board will hear and make deter- minations upon any proceeding before the Board as- signed by the Board to the ALJ. AIJ makes a report of final dispostion to the Board. Report of ALJ becomes final order of Board within 30 days unless a party ap- peals to the Board or a Board member directs that mat- ter come before the Board. H1. (e) Circuit Court review "Any person" aggrieved by final order of GHPRB may obtain review in U.S. court of appeals for the circuit in which "violation occurred or employer resides or trans- 42 acts business". Action must be filed within 60 days of date of GHPRB's final order (or upon expiration of 30- day review period). Copies of petition filed with court, GHPRB, other parties. GHPRB files hearing record with court. Court has jurisdiction to affirm, modify, or set aside, in whole or in part, order of the Board and power to enforce the order. Order may be modified or set aside only to extent order is determined to be "arbitrary or ca- pricious". H.L.C. UNIVERSAL MEDICAL CARE (UNIMED) ACT OF 1992 MediWorkers Component of UniMed [Title I]-Enforcement and Related Administrative Issues Issue/Topic Policy Notes FHBC\ UNIMED Additional enforcement actions (a) Civil enforcement actions by HBA, FHBEC, etc. -Brought by HBA to enjoin any act or practice which -Note that actions are brought against "insurers" here violates any provision of title V of ERISA or to obtain and not "plans". any other appropriate legal or equitable relief to redress Also, A2 provides for administrative enforcement of em- such violations or to enforce any provisions of title V. ployer mandate itself. -HBA may assess civil penalties against plans (includ- ing self-insured employers) of up to $1,000 a day from date of plan failure or refusal to meet prescribed report- ing requirements (including under A2.(b)). HBA may bring civil action to collect. Amounts collected used ex- clusively for ERP. -The Federal district courts have exclusive jurisdiction of civil actions under title V. Cases may be brought in district where plan is administered, breach took place, or defendant resides or may be found. No amount in contro- 43 versy requirement. -Reasonable attorney's fees to prevailing party. -Authority to sue to be delegated to FHBEC, SC, etc. with respect to matters within their jurisdiction. (b) Actions against HBA, etc. by employees, employ- Suits by employees and beneficiaries, by employers, and , and plans by plans to review final orders of HBA, FHBEC, elc., re- strain HBA, FHBEC, etc. from taking any action con- trary to title, compel HBA, FHBEC, etc. to take action required under title, brought in the distict court for dis- tricl where plan has principal office or DC H.L.C. February 20, 1992 (12:50 p.m.) UNIVERSAL MEDICAL CARE (UNIMED) ACT OF 1992-Continued MediWorkers Component of UniMed [Title I]-Enforcement and Related Administrative Issues Issue/Topic Policy Notes FAFHBC\UNIMED H2. (c) Actions between employers and insurers Federal cause of action in Federal district court by in- surer against employer and by employer against insurer to enforce contractual terms. Insurer's plan may termi- nate coverage of employer's employees for cause, such as nonpayment of premiums in accordance with permitted terms of plan. The ERP under the Special Counsel of the HBA is available for settlement out of court. Settlement agreements obtained under ERP enforceable in Federal district court (Bee H1. (c)(11) -4.). State causes of ac- tion are preempted. 44 H.L.C. UNIVERSAL MEDICAL CARE (UNIMED) ACT OF 1992 MediWorkers Component of UniMed [Title I]-Enforcement and Related Administrative Issues Issue/Topic Policy Notes F:\FHBC\UNIMED 13. Effect of enforcement provisions. 13. (a) HBA and Group Health Plans -Plan (or self-insured employer) must provide HBA a certification of insurance for each contracting employer on timely basis on behalf of employer. -Certification of insurance (1) demonstrates that plan continues to meet qualification requirements during the reporting period, and (2) Bele forth identity of employers who either have made payments-or assumed obliga- tions to a plan to make payments-necussary to provide required coverage to employees during reporting period, or have developed reserves to provide for such coverage ---HBA must issue to qualified plan a qualification let- ter upon demonstrating meeting of qualification require- ments. -HBA may assess fines for fuilure to comply with re- 45 porting requirements of lilla. -In the case of an insured plan that fuiled to meet B2. requirements or to cover an employer that has tendered (or offered to tender) premlums, HBA can seek specific performance and impose a fine (of up to $1,000 per day). --HBA may sue group health plan in Federal district court for appropriate legal or equituble relief to enforce requirements of title. -Plan may sue HBA for qualification letter and for other appropriate legul or equitable relief to enforce re- quirements of title. 13. (b). HBA and employers -Premium surcharge of 50% payable to HBA by em- ployer (or by plan on behalf of employer) for failure to provide timely certification of insurance to HBA -HBA may sue employer in Federal district court for appropriate legal or equitable relief to enforce require- ments of title. H.L.C. UNIVERSAL MEDICAL CARE (UNIMED) ACT OF 1992-Continued MediWorkers Component of UniMed [Title I]-Enforcement and Related Administrative Issues Issue/Topic Policy Notes F:\FHBC\UNIMED F:\FHBC\ UNIMED 13. (c) HBA and employees -Employees have right of action against HBA to carry [Review this provision] out responsibilities under title, similar to action allowed under §502(k) of ERISA. 13. (d) FHBEC and group health plans (and employers Qualified plans must provide FHBEC timely informa- n the case of self-insured plans) tion concerning the payroll of the employer, including in- formation defining the fulltime workforce and other data relevant to determination of applicable capitation rates. Together with such data, the plan must provide data necessary to determine extent to which payments for services under the plan have or have not exceeded capi- tation rates. -FHBEC may sue plans (including employers provid- ing self-insured plans) in district court for failure to pro- vide relevant data on covered employees (and spouses). Fines may be assessed. 46 -FHBEC may sue plans (including employers provid- ing self-insured plans) in district court for unpaid equali- zation payments based on capitation rates. Equalization payments treated same as tax liens (in establishing pri- ority in bankruptcy and for purposes of collection). -Plans (including self-insured employers) may sue FHBEC in district court for unpaid equalization rebates. H3. (e) Plans and employers -Insured plan must provide the employer at least an- nually a certification that the plan is qualified. Employ- ers held harmless for reliance on such certification. -Federal cause of action in Federal district court by in- surer against employer and by employer against insurer to enforce contractual terms. Insurer's plan may termi- nate coverage of employer's employees for cause, such as nonpayment of premiums in accordance with permitted terms of plan. Settlement agreements obtained in ERP enforceable in Federal district court. State causes of àc- tion are preempted. H.L.C. UNIVERSAL MEDICAL CARE (UNIMED) ACT OF 1992 MediWorkers Component of UniMed [Title I]-Enforcement and Related Administrative Issues Issue/Topic Policy Notes \FHBC\ \FHBC\UNIMED UNIMED Miscellaneous enforcement and administrative visions. (a) Plan claims procedures A counterpart to ERISA § 503 will appear in title V, re- quiring mimimum standards for procedures under the plan for reviewing benefit claims. The provision will be strenghened to allow a maximum of 60 days for initial determinations by the plan, and " maximum of 60 days to respond to appeals of such determinations. Failure to respond within the time limit will be deemed a denial of the claim. (b) Investigative authority in HBA Investigative authority will be granted to HBA, subject to delegation to FHBEC, etc. Authority similar to §504 of ERISA. (c) Regulatory authority HBA will have broad regulatory authority, similar to 47 § 505 of ERISA, subject to delegation to FHBEC, etc. (d) Coordination with other agencies Provision similar to § 506 of ERISA (e) General applicability of APA Provision similar to 507(a) of ERISA applicable where appropriate. (f) Conflict of interest in Govt. employees prohibited Provision similar to § 507(b) of ERISA (g) Authorization of appropriations Provision similar to §508 of ERISA (h) Interference with rights protected under title Provision similar to § 510 of ERISA (i) Coercive interference Provision similar to §511 of ERISA, including prohibi- tion of discrimination based on health status (j) Research, studies, annual report Provisions similar to § 513 of ERISA (k) Lien for liability Rules governing lien for liability should be patterned after § 4068 of ERISA, while ensuring proper treatment in bankruptcy. (1) Limitations on causes of action Follow rules generally applicable under ERISA (6 year/ 3 year Instation) H.L.C. 112.50 Fahriary , 3 3 10Q2 - UNIVERSAL MEDICAL CARE (UNIMED) ACT OF 1992-Continued MediWorkers Component of UniMed [Title I]-Enforcement and Related Administrative Issues Issue/Topic Notes F:\FHBC\UNIMED Policy H4. (m) Criminal provisions Criminal code provisions currently applicable to ERISA violations expanded to include references to new title V provisions. 48 H.L.C. UNIVERSAL MEDICAL CARE (UNIMED) ACT OF 1992 MediWorkers Component of UniMed [title I]-Miscellaneous Issue/Topic Policy Notes F:\FHBC\UNIMED MISCELLANEOUS [subtitle B of title I) 11. Preemption of State provisions The term "State" includes all States and territories. (a) Preemption of State Benefits Mandates State law cannot require benefits other than the basic required benefits. 1. (b) Preemption of State Restrictions on Managed or State cannot impose certain restrictions on bona fide - Coordinated Caro network plans nor on proper utilization review pro- grams. 2. Repeal of COBRA continuation requirements -|Cross-reference only here; repeal of ERISA, IRC, and PHSA provisions would be in title IX] 1. Increase Deduction for expenses for self-om- [Would extend current 25% deduction through 1/1/95; [Cross-reference only here; provision to appear in title loyed us of that date would increase to 100%, but limit to ex- VI (linancing).) penses for required health benefits only.] 49 H.L.C. UNIVERSAL MEDICAL CARE (UNIMED) ACT OF 1992 MediKids Component of UniMed [title II] Issue/Topic Policy Notes F:\FHBC\UNIMED A. ELIGIBILITY/ENTITLEMENT (Subtitle A) Extension of MediWorkers component, providing cover- Disabled children may also be eligible for benefits age to all children residing in the U.S. who are under 22 under the medicare program, but medicare benefits years of age, regardless of employment or education sta- would be secondary to MediKids benefits. tus. Enrollment at birth or time of immigration; enrollment not prerequisite to receive services or benefits. In order to provide for initial enrollment, would require schools and Head Start programs and (under medicare) hospitals to enroll individuals beginning September 1, 1994. Births on or ufter 1/1/95 in medicare hospitals would be automatically recorded. All children immigrut- ing to the U.S. would be enrolled at time of entry or ad. justment of status. However, children covered under current collective bar- gaining agreements would not be covered until agree- ment expired (not counting any extensions). 50 B. REQUIRED BENEFITS [Subtitle B] Employer's group health plan can supplement benefits; but benefits under MediKids component are primary. B1. Services H.L.C. 1. (a) Basic Services Except as specified, would include the MediWorkers "core" service package, including- -inpatient hospital services (subject to 45 day annual limit for inpatient mental health services), except that F.\FHBC\UNIMED FHBC\ UNIMED preadmission authorization would be required for inpa- tient mental health services and no admission would be approved if could adequately treat as un outpatient; -physicians services and community health clinic Berv- ices; -mentul health services (but with outpatient limit of 40 visits per year, rather than 20 under MediWorkers component of UniMed); -ulcohol and drug abuse treatment services; -pregnancy-related services; -laboratory and diagnostic tests; & -caHe management services. 1. (b) Additional MediKida Services Would include the following additional services (subject to a periodicity schedule established by HBA in consulta- tion with the American Academy of Pediatrics): -periodic screening services, including comprehensive 51 physical examinations, age appropriate immunizations, laboratory tests, and health education; -vision services, including screening and corrective eyeglasses or lenses; -dental services, including screening and preventive dental and corrective dental services; and -hearing services, including screening and hearing aids. Would also include prescription drugs, including insulin and medically appropriate nutritional supplements. Would also include the following (if part of plan of care prescribed by H physician): -treatment of developmental and learning disabilities (other than the educational component); and -speech, occupational, and physical therapy. HBA would examine (and report to Congress) concerning the appropriateness of providing coverage for long-term care services under the MediKids component of UniMed. H.L.C. February 20, 1992 (12:50 p.m.) UNIVERSAL MEDICAL CARE (UNIMED) ACT OF 1992-Continued MediKids Component of UniMed [title II] Issue/Topic Policy Notes F:\FHBC\UNIMED B2. Deductible Under age 18, none would apply. At age 18, there would be a deductible of $150, indexed to SSA wage base (as with MediWorkers' deductible) B3. Coinsurance None for children under 3 or for pregnancy-related services or preventive services. For other services, copayment schedule for children 3- 11 (like $5 per outpatient visit) and 20 percent coinsur- ance for children 12 and older. B4. Limit on Cost-Sharing $1,500 per kid, indexed by increases in SSA wage base. C. PAYMENTS FOR SERVICES [Subtitle C] Single payor model (like medicare). C1. Payment Rates HBA to establish payment rates based on reference payment rates established under MediWorkers compo- nent of UniMed, with appropriate modifications to reflect children-only coverage under the MediKids component. 52 For services not covered, will establish appropriate schedule based on concepts used in establishing MediWorkers reference payment rates. HBA to establish such additional, special advisory com- mittee or committees as may be appropriate to establish these rates. Payment methodology will be similar to medicare pro- gram. C2. Payment Method Assignment is mandatory. Violations subject to exclusion under MediKids and UniMed components of UniMed, as well as civil mone- tary penalties. D. MISCELLANEOUS [Subtitle D] For Cost-Containment features, see below. D1. Funding Financing for MediWorkers children through These financing methods take into account ability to MediWorkers premiums. (See B1 under Financing [Title pay. VII) and for MediWrap children through addition to MediWrap premiums (see C1 under Financing [Title VII). H.L.C. D2. Use of Intermediaries As in medicare, except HBA would do the contracting for fiscal administration. Would permit States to administer. F-\FHBC\UNIMED D3. Treatment of HMO's and Capitation HBA would be authorized to contract with HMO's under a capitation contract in manner comparable to au- thority of HHS to contract on a risk basis with HMO's under the medicare program, except that -payment rate would be 100 percent (rather than 95 percent) of the adjusted average per capita cost (or AAPCC) for children, -plans could be "kids-only" plans (e.g., school-based programs), and -plans have an affirmative obligation to follow up on conditions detected through screening. In addition, HBA would establish an optional primary care capitation payment methodology under pediatric group practice arrangements (and for pediatricians in other cases specified by HBA). : D4. Relation to Medicare & Medicaid Programs Primary payor to medicare and medicaid programs. [For State financial maintenance of effort requirement, States would be required to maintain effort in terms of 53 see title VI (Financing).] eligibility and benefits for children (above those provided under MediKids component of UniMed). This would not duplicate low-income assistance. D5. Enforcement Covered individuals have access to Early Resolution Program (ERP) and claims review procedures established as part of MediWorkers component of UniMed. H.L.C. UNIVERSAL MEDICAL CARE (UNIMED) ACT OF 1992 MediWrap Component of UniMed [title III] Issue/Topic Policy Notes F:\FHBC\UNIMED UNIMED A. ELIGIBILITY/ENTITLEMENT [Subtitle A] All legal permanent residents aged 22 through 59 who cannot establish coverage under medicare (as disabled) or under a qualified employer health plan (as a full-time employee or spouse). Eligible individuals aged 22 through 59 will be deemed enrolled unless can establish other coverage. Medicare is secondary payor for disabled and ESRD in- dividuals. Effective January 1, 1995, except will not apply to indi- viduals provided health coverage under a current collec- live bargaining agreement until such agreement expires. B. BENEFITS (including deductibles, coinsurance, etc.) [Same as basic services under MediWorkers component) Employers can supplement benefits for part-time and Subtitle B] seasonal workers. C. PAYMENTS FOR SERVICES [Subtitle C] Single payor model (like medicare). 54 C1. Payment Rates HBA to establish payment rates based on reference payment rutes established under MediWorker component of UniMed, with appropriate modifications to reflect pop- ulation covered under the MediWrap component. HBA to establish such additional, special advisory com- mittee or committees as may be appropriate to establish these rates. Payment mothodology will be similar to medicare pro- grain. C2. Payment Method Assignment is mandatory. Violations subject to exclusion under MediWrap and MediKids components of UniMed, as well as civil mone- lary penalties. ). MISCELLANEOUS [Subtitle D] H.L.C. 1. [Premiums] (There would be a monthly actuarially - cermined na- -For details, see financing title, as the premium tional community-rated premium subject to an income would be collected through income tax system.] related cap. Part-time and seasonal employees would re- ceive credit for both the employer and employee amounts FHRC\ UNIMED of the UniMed part-time/seasonal payroll tax paid, as well as any part of the Health Care equalization self-em- ployment tax paid.) 12. Use of Intermediaries As in medicare, except HBA would do the contracting for fiscal administration. Would permit States to administer. 13. Treatment of HMO's HBA would be authorized to contract with HMO's under risk-bused contract in manner comparuble to au- thority of HHS to contract with HMO's under medicare program, except that -payment rate would be 100 percent (rather than 90 percent) of AAPCC (adjusted average per capita cost), and -plans could be 100 percent MediWrap. 14. Relation to Medicaid Program Primary payor to medicaid. [For State financial maintenance of effort requirement, 55 Medicaid could supplement these benefits. see title VI (Financing).) )5. Enforcement Covered individuals have access to Early Resolution Program (ERP) and claims review procedures established as part of MediWorkers component of UniMed. H.L.C. UNIVERSAL MEDICAL CARE (UNIMED) ACT OF 1992 Cost Containment and Quality Control [title IV]-MediWorkers Component of UniMed Issue/Topic Policy Notes F:\FHBC\UNIMED A. DETERMINATION OF PREMIUMS BASED ON [This is specified in title 1 and is cross-referenced here MEDIWORKERS NATIONAL premium PERCENT- for informational purposes.] AGE (MNPP); USE OF CAPITATION RATES B. PAYMENT LEVELS [HBA establishes maximum charge levels.) [This is specified in title I and is cross-referenced here for informational purposes.] C. CONTROLS ON CAPITAL EXPENDITURES [HBA can reduce maximum charge levels to reflect ex- (This is specified in title I and is cross-referenced here cessive increases in capital expenditures by hospitals.] for informational purposes.] D. ENCOURAGING USE OF "MANAGED" OR "CO- ORDINATED" CARE D1. Encouraging Use of "Network" Plans [Payment based on capitation and preemption of State [This is specified in title I and cross-referenced here for anti-managed care laws.] informational purposes.] D2. Encouraging Use of Utilization Review. [Preemption of State anti-managed care laws.] (This is specified in title I and cross-referenced here for informational purposes.] 56 D3. Use of practice guidelines & Outcomes re- Current Federal outcomes-related research, through the search Agency for Health Care Policy and Research, would be expanded to cover employer health plans. FHBEC would set aside an appropriate percentage of MediWorkers pre- miums to fund an appropriate share of expenses for out- comes research. Plans could deny benefits for services that are not pro- vided in accordance with practice guidelines which HBA has recognized for application. Any practice guidelines would be adjusted over time, taking into account feedback from local quality monitor- ing boards (see below). D4. Quality Control Mechanisms Policy.-The concept here is to provide for a dynamic process of locally-driven, consumer-oriented information, to serve as " counter-bulance to the significant incentives that capitation provides for cutting costs. H.L.C. D4. (a) National Quality Advisory Board HBA would establish a national advisory committee on quality standards, to advise HBA concerning substand- ard plans and to provide guidance and technical assist. ance to local advisory boards. F:\FHBC\UNIMED HBA would establish national quality standards, in- cluding standards to monitor the use of preauthorization review and other utilization review and network con- trols. HBA could establish additional requirements that network plans and utilization review programs would have to meet in order to be exempt from any State anti- managed care laws. D4. (b) Use of Local Quality Review Boards HBA would provide for establishment of local quality review monitoring advisory bodies, with representation of employers, labor organizations, and individuals. The bodies would be provided locality-specific information (collected by FHBEC) on a non-individually-identifiable basis on utilization and quality of services under differ- ent plans in a community or service area. These bodies would- (1) provide feedback to plan sponsors (in order to im- 57 prove performance), (2) provide feedback to HBA (in order to take appropri- ate actions in the case of substandard performance), and (3) provide information to employers (and labor organi- zations) that is useful in improving marketplace deci- sionmaking by taking into account quality measures in the selection of a qualified group health plan. Local advisory boards would have access to quarterly reports supplied by plans to FHBEC. H.L.C. UNIVERSAL MEDICAL CARE (UNIMED) ACT OF 1992-Continued Cost Containment and Quality Control [title IV]-MediWorkers Component of UniMed Issue/Topic Policy Notes F:\FHBC\UNIMED D4. (c) Financial Monitoring In order to protect beneficiaries and the FHBEC sys- tem, as a condition of qualification plans would be re- quired to have adequate reserves or otherwise meet fi- nancial solvency standards specified by HBA. There would be quarterly financial reports by each plan (in order to catch plans before they become insolvent). Beneficiaries are held harmless for bad debts resulting from failure of plans to make payment for services; pro- viders must look to plun for most payment. Once a plan is declared insolvent, HBA would establish procedure for temporary assignment of individuals to another plan (which could be MediWrap] pending employer selection of a new plan. E.IMPROVEMENTS IN ADMINISTRATIVE EFFI- [These would also apply under the MediKids and CIENCY UniMed components of UniMed.] 58 E1. Uniform Claims Forms & Electronic Billing All plans would have to use a uniform claims form and, as may be required by the HBA, uniform electronic bill- ing standards. E2. Uniform Health Care Cards Health care enrollment cards would have to be electron- ically coded for uniform input, as prescribed by HBA. F. MEDICAL MALPRACTICE REFORM HBA would report to Congress on specific steps that could be taken to improve system. More specificully, under the MediWorkers component of UniMed HBA would examine the feasibility of using the ERP (early resolution process) as a means of alternative dispute resolution. H.L.C. UNIVERSAL MEDICAL CARE (UNIMED) ACT OF 1992 Cost Containment [title IV]-MediKids and MediWrap Components of UniMed Issue/Topic Policy Notes F:\FHBC\UNIMED G1. Payment Rates [Under MediKids and MediWrap components of [Provisions to be in titles II and III and cross-refer- UniMed, mandatory rates are established using medi- enced here for informational purposes.) care payment methodology.] G2. Encouraging Use of "Managed" or "Coordinat- od" Care G2. (a) Encouraging Use of "Network" Plans [Permit enrollment in HMO's and similar prepayment [Provisions to be in titles 11 and III and cross-refer- plans (under capitation-like conditions, such as under enced here for informational purposes.] medicare).] [In addition, under the MediKids component of UniMed, there would be demonstrations of use of school- based networks as well D8 primary care capitation dem- onstration projects.] G2. (b) Encouraging Use of Utilization Review. Under MediKids and UniMed components of UniMed, HBA would be authorized to contract with PRO's in 59 manner similar to how medicare operates if it deter- mines it to be cost-effective. G2. (c) Use of Practice Guidelines & Outcomes Research Expand current Federal outcomes research, through the Agency for Health Care Policy and Research, to cover MediKids and MediWrap components of UniMed. MediKid and MediWrap trust funds would pay their fair share (based on the proportion of national health care expenditures made under the programs). HBA is authorized to deny benefits for services that are not provided in accordance with practice guidelines which HBA has recognized may be applied. G3. Improvements in Administrative Efficiency [These are the same as under MediWorkers compo- nent.] G3. (a) Uniform Claims Forms & Electronic Billing MediKids and MediWrap components of UniMed would have to use a uniform claims form and any uniform elec- tronic billing standards that are used under employer plans. H.L.C. UNIVERSAL MEDICAL CARE (UNIMED) ACT OF 1992-Continued Cost Containment [title IV]-MediKids and MediWrap Components of UniMed Issue/Topic Policy Notes F:\FHBC\UNIMED G3. (b) Uniform Health Care Cards MediKids and MediWrap components would have health care enrollment cards which meet MediWorkers component standards. G4. Medical Malpractice Reform In addition to study provided under MediWorkers com- ponent of UniMed [namely study of alternatives and im- provements), HBA would establish the use of ERP (early resolution process) as M means of alternative dispute resultion under the MediKids and MediWrap compo- nents. 09 H.L.C. UNIVERSAL MEDICAL CARE (UNIMED) ACT OF 1992 Low-Income Assistance [title V] Issue/Topic Policy Notes F.\FHBC\UNIMED 1 PREMIUM ASSISTANCE 1. MediWorkers Component of UniMed No Federal subsidy. [Program is progressively financed, with at least 80 percent of premium paid by employer; no additional sub- Bidy required.] 2. MediKids Component of UniMed [See Financing: certain premiums limited to percent of There are no direct premiums (so no explicit low-income income.] $100 fee for entering the Early Resolution Pro- assistance needed) gram is waived. 3. MediWrap Component of UniMed [See Financing: premium is limited to a percent of in- come.] $100 fee for entering the Early Resolution Pro- gram is waived. DEDUCTIBLES AND COINSURANCE ASSIST- Throughout the UniMed Program (comprising NCE MediWorkers, MediKids, and MediWrap components), assistance for deductibles and coinsurance for required services would be based on adjusted gross income (in- 61 cluding joint income for couple). There would be no deductibles and coinsurance for those with income below 100 percent of poverty line; the deductibles and coinsur- ance would be phased out until there is no low-income assistance for individuals with income above 200 percent of the poverty level. H.L.C. UNIVERSAL MEDICAL CARE (UNIMED) ACT OF 1992-Continued Low-Income Assistance [title V] Issue/Topic Policy Notes F:\FHBC\UNIMED APPLICATION PROCESS [This process would be similar to low-income assistance Upon application, an individual may obtain a reduction process provided under S. 1177.) of deductibles and coinsurance during a year. The indi- [The program of financial assistance to qualified medi- vidual could submit a 1040-like estimated income state- care beneficiaries would continue under the medicaid ment. Based on the statement, assistance to reduce the program.] deductibles and coinsurance could be provided. Falsifica- tion of the statement would be subject to penalty. Any- one provided assistance based on an estimate would be required to file an income tux return (or 1040-like infor- mation return) for the year in which assistance provided. The amount of assistance would be adjusted based on the final income for the year with the individual making restitution (or being provided additional assistance) based on the return. Instead of receiving a direct reduction of deductibles and coinsurance, an individual may apply at the end of the 62 year, through the filing of a 1040 tax return (or 1040- like information return) for a rebate of excess deductibles and coinsurance bused on income during the year. H.L.C. UNIVERSAL MEDICAL CARE (UNIMED) ACT OF 1992 Financing [title VI]-MediWorkers Component of UniMed Issue/Topic Policy Notes ".\FHBC\UNIMED MEDIWORKERS COMPONENT OF UNIMED Use of Payroll-Based premium [These provisions will be in ERISA provisions and would merely be referenced here] 11. Employer/ee share Employer pays a total premium to health plan based on the MediWorkers National Premium Percentage (MNPP) of total payroll computed by HBA. However, the wages counted cannot exceed twice the maximum wage level subject to Social Security taxes (approx. $125,000). Employer may charge the employee based on a percent- age of wages (but percentage may not be greater than 1/5 of the MNPP specified by HBA). [If employer pays share, would be treated the same as payment for health insurance benefits now. Probubly no specific provision needed, if this is clearly a premium.] 12. Treatment of Self-Employed [See MediWrap component, C3 below.] 63 L3. Treatment of Children and Part-Time and Sea- For treatment of children, see MediKids component at nal Workers B4 below. For treatment of part-time and seasonal work- ers, see MediWrap component at C4 below. 14. Effective Date and Maintenance of Employer MediWorkers premium would be paid in each month Note that employees will receive benefits in January fort (beginning with January 1995) based on remuneration 1995 based on employment status in December 1994. paid during previous month (viz., beginning with Decem- ber 1994). MAINTENANCE OF EFFORT.-The premiums would not be required for remuneration of individuals provided health care coverage under a collective barguining agreement entered into before date of enactment. 5. Funding Early Resolution Program and Admin- Annual user fee charged to insurers (including self-in- trative Review Process surers) at $0.05 per insured person, to be used exclusive- ly for funding ERP and administrative review process. There is also $100 fee per party under the ERP. 3. Funding Transitional Premium Subsidy for Other Federal revenues. wall Business H.L.C. February 20, 1992 (12:50 p.m.) UNIVERSAL MEDICAL CARE (UNIMED) ACT OF 1992 Financing [title VI]-MediKids Component of UniMed Issue/Topic Policy Notes F:\FHBC\UNIMED B1. MediKids Element of the MediWorkers National In recognition of coverage to be provided under UniMed In essence, a QGHP provides benefits for the children Premium Percentage (MNPP) to workers' children, the MNPP paid to group health of covered workers through payment of a MediKids em- plans under the MediWorkers component would include ployment-based premium to FHBEC. A QGHP cannot a portion to be directed to funding the MediKids compo- elect to cover children directly under the plan, rather nent. This would be provided in the terms of group than paying the MediKids premium. health plans as a requirement for a qualified group A QGHP could supplement benefits available to chil- health plan (QGHP). dren of workers, just as it can supplement basic benefits for workers. B1. (a) Determination of Aggregate Amount to be Collect- HBA would estimate the total cost for the year under ed Through Premium the MediKids component for children of adults covered under MediWorker component. This would be done by multiplying (1) the average number of children under the MediKids component in the year who are the children of workers (or spouses) covered under the MediWorker component, by (2) the es- 64 timated average per capita cost under MediKids. B1. (b) Payment of MediWorkers National Premium In setting the appropriate level of the MNPP, the HBA This augmented MNPP would also be applied in com- Percentage under MediWorkers Component as Element would add a percentage determined to be required to puting the additional taxes to finance low-income assist. of Funding for MediKids Component raise the MediWorkers element of funding MediKids ance under title VI.E. computed under B1.(a) above. In applying the MNPP 80 computed under the MediWorkers component, this additional element of funding for the MediKids component would aulomatical- ly be shared 80/20 between the employer and employees. As under MediWorkers, an employer's payment of the employee share of the MediKids component would not be considered taxable income to the employee. B1. (c) Collection by Group Health Plans and Allocation By incorporation as part of the MNPP, this element of to MediKids through Equalization Process funding for the MediKids component is collected in due course through payment to qualified health benefit plans and then forwarding to FHBEC (through the equaliza- tion process). FHBEC would then forward the portion of the MNPP attributable to the MediKids element to the MediKids trust fund. H.L.C. B2. MediKids Element of MediWrap Premium This element would not apply to children whose parents are full-time workers because the parents pay premiums for their children through the MediWorker program. F:\FHBC\UNIMED B2. (a) Amount of Flut Monthly Premium Element As part of the MediWrap premium for individuals who The monthly premium element is basically the average are not covered through the MediWorker component and monthly per child cost of MediKids for the year. who have a child covered under MediKids, there would be a MediKids premium element equal to a nationally specified community-rated actuarial premium to be es. tablished by HBA for each child under the MediKids component of UniMed. There would be no variation by age, sex, marital status, etc. The premium component would be computed on a monthly basis (as is the case for the MediWrap premium for adults). B2. (b) Payment of Premium Element Parents would be required to pay the premium element Low-income assistance would be available to eliminate each year in conjunction with the payment of the or reduce the premium element, in the same manner as MediWrap premium. Insofar as it is included as part of B for the MediWrap premium for the parent. MediWrap premium- (1) in the case of children of part-time and seasonal workers, parents would receive a credit against the pre- 65 mium in the amount of the employer/employee equaliza- tion tax paid (but there would be no refund for excess employer/employee taxes paid), and (2) in order to provide protection to low-income indi- viduals, a family's premium (including MediWrap and MediKids elements) could not exceed the MNPP of total, gross income (including joint income of married couple) for members of the fumily. B2. (c) Collection of Premiums Premiums would be collected in the same manner as premiums under the MediWrap component. B3. State Medicaid "Maintenance of Effort" Pay- States are required to pay the MediKids component a Effective for calendar quarters beginning on or after ient "maintenance of effort" amount. January 1, 1995. H.L.C. February 20, 1992 (12:50 p.m.) UNIVERSAL MEDICAL CARE (UNIMED) ACT OF 1992-Continued Financing [title VI]-MediKids Component of UniMed Issue/Topic Policy Notes F:\FHBC\UNIMED B3. (a) Computation (1) Medicaid Eligibles.-HBA would determine, based on the law as of January 1, 1992 (including changes in eligibility scheduled to occur after that date) and for each calendar quarter beginning on or after January 1, 1995, the average number of individuals in the State who are entitled to MediKids and who would have been entitled to medicaid assistance in the quarter. (2) Per capita MediKids payments.-For each quarter, the Secretary would estimate the average per child ex- penditures to be made in the quarter in the State under the MediKids component. (3) Maintenance of Effort Amount.-The maintenance of effort amount is the product of (1) and (2) multiplied by 1 minus the Federal Medical Assistance Percentage (FMAP) under the medicaid program. 66 B3. (b) How Paid States required, as a condition of receiving funds under the Elementary and Secondary Education Act for each calendar quarter beginning on or after January 1, 1995, to pay the maintenance of effort amount. H.L.C. B4. Trentment of Workers under Age 22 There would be a payroll-based tax computed for work- This tax is in the nature of an "equalization" tax 80 ers under age 22 equal to the MediWorkers National that, taking also into account the similar tax for part- Premium Percentage (MNPP) of their wages. The tax time and seasonal employees, from an employer's per- F:\FHBC\UNIMED would have a ceiling of twice the maximum level of spective, wages of all employees (whether full-time adult, wages subject to the Social Security tax. child, or part-time or scasonal) are effectively subject to Payroll-related Laxes paid in for wages of children (re- a premium or tax or similar amount. gardless of whether they are full-time, part-time, or sea- There would be a need for coordination between the sonal), (viz., who are not covered under employer plan,] IRS (collecting this Lax) and FHBEC (which has informa- would be credited to MediKids Trust Fund. tion on health care enrollment for everyone). Payroll An employer may pay all or a portion of the employee's would have to be reported with some indication or other share of the payroll-based Lux, and this payment would method of identifying those individuals who are covered not be included in income of the employee [so would under the 3 different components of UniMed. This would treat payroll tax the same way as health care premiums be important in assuring individuals receive appropriate are currently treated]. credits under the MediWrap component. Effective for remuneration paid on or after January 1, 1995. B5. Additional Federal Funds Additional Federal funds would come from previous general revenues dedicated to medicaid and from other Laxes (to be specified). 67 H.L.C. UNIVERSAL MEDICAL CARE (UNIMED) ACT OF 1992 1003 3 , Financing [title VI]-MediWrap Component of UniMed Notes F:\FHBC\UNIMED Issue/Topic Policy C. MEDIWRAP COMPONENT OF UNIMED C1. Actuarial Premium Collected Through In- come-Tax System Nationally specified community-rated monthly actuariul In the case of MediWrap beneficiaries with children, C1. (a) Amount of Premiums premium to be established for each individual (no family the amount of the premium would be increased to in- premium). There would be no variation by age, sex, mar- clude a MediKids element. See B2(a) above. ital status, etc. C1. (b) Limit on Amount of Premium to MNPP of In order to provide protection to low-income individuals, For low-income workers, practical net effect of this limit the MediWrap premium (including any MediKids ele- (and crediting for employment equalization taxes paid) Total, Gross Income ment) could not exceed the MediWorkers National Pre- would be to limit premium to the MNPP of non-wage in- mium Percentage (MNPP) of total, gross income (includ- come (viz., interest and dividends), which is usually ing joint income for a married couple and any children's small. income). In case of coverage during purt of a year, the total, 68 gross income would be proruted based on number of months of coverage. C1. (c) Crediting MediKids and MediWrap Equaliza- There would be credited against MediWrap premium tion Employment Taxes and MediWrap Self-Employment amount (including any MediKids element), total Taxes MediWrap and MediKids equalization taxes paid (includ- ing both employer and employee shares), see C4 below, and self-employment taxes, see C3 below. However, if the amount of taxes exceeds the amount of the premium, the taxes would not be refunded. To be paid with income taxes (including provision in es- Effectively, low-income individuals not now required to C1. (d) Collection timated taxes). file a tux return will be required to file information re- turn to obtain relief from full MediWrap premium (in- cluding any MediKids element). Would be payable for months in which individuals cov- ered under MediWrap component of UniMed beginning with January 1995. 41 1e Medicaid "Maintenance of Effort" Pay. States are required to pay the MediWrap component of Effective for calendar quarters beginning on or after UniMed a "maintenance of effort" amount. January 1, 1995. H.L.C. C2. (a) Computation (1) Medicaid Base Payment.-HBA would determine the average quarterly amount expended under the State medicaid plan (including Federal and State share) for in- dividuals eligible for MediWrap component of UniMed F:\FHBC\UNIMED F:\FHBC\ UNIMED during a base year (probably 1992) for services covered under that component. (2) Updating for trend in expenses.-The buse payment under (1) would be trended forward to reflect (for periods before January 1, 1995), average, per capita medicaid ex- penditures for the population and types of services de- scribed in (1) and, for subsequent periods, by the average per capitu growth in program expenditures under the MediWrap component of UniMed in the State up to the quarter involved. (3) Maintenance of Effort Amount.-The maintenance of effort amount is the amount determined under (2) multi- plied by 1 minus the Federal Medical Assistance Per- centage (FMAP) used under the medicaid program. C2. (b) How Paid States required, as a condition of receiving funds under the Job Training Partnership Act for each calendar quar- 69 ter beginning on or after January 1, 1995, to pay the maintenance of effort amount. H.L.C. February 20. 1992 (12:50 p.m.) UNIVERSAL MEDICAL CARE (UNIMED) ACT OF 1992-Continued Financing [title VIJ-MediWrap Component of UniMed Notes F:\FHBC\UNIMED Issue/Topic Policy C3. MediWrap Employment Equalization Tax for There would be a payroll-based Lax computed for part- This tax is in the nature of an "equalization" Lax 80 Part-Time and Seasonal Workers time and seasonal workers, equal to the MediWorkers that, taking into account the similar tax for workers National Premium Percentage (MNPP), including the under age 22, from an employer's perspective, wages of MediKids element, of their wages. The tax would have a all employees (whether full-time adult, child, or part- ceiling of twice the maximum level of wages subject to time or seasonal) are effectively subject to a premium or the Social Security tax (approx. $125,000). Lux or similar amount. Payroll-related taxes paid in for part-time and seasonal There would be a need for coordination between the workers (other than children) would be credited to IRS (collecting this tax) and FHBEC (which has informa- MediWrap and MediKids trust funds for premiums of tion on health care enrollment for everyone). Payroll those workers (allocated in proportion to the amounts of would have to be reported with some indication or other the MNPP attributable to the MediWorkers and method of identifying those individuals who are covered MediKids components); except that (1) IRS would identi- under the 3 different components of UniMed. This would fy the social security number of those workers who are be important in assuring individuals receive appropriate covered under the MediWorkers component of UniMed credits under the MediWrap component. and will transfer such Laxes to the FHBEC for equaliza- 70 tion purposes, and (2) for workers without children, the MediKids trust fund would only receive its allocation if the combined MNPP exceeds the MediWrap premium. An employer may pay all or a portion of the employee's share of the payroll-based tax, and (as under the MediWorker component) this payment would not be in- cluded in income of the employee. Effective: For remuneration paid on or after January 1, 1995. C4. MediWrap Tax on Self-Employment Income Tax on self-employment income, equal to the This is similar to MediWrap employment equalization MediWorkers National Premium Percentage (MNPP) (up tax 80 that self-employment income and wages are treat- to twice the maximum wages subject to Social Security ed similarly. taxes, viz., approx. $125,000). This is non-refundable. Funds are credited against MediWrap premium (includ- ing any MediKids element). This Lox is non-refundable. Effective: Taxable years ending after December 31, 1994; except would pro-rute to reduce Lax BO as to make it not applicable for portions of tax years beginning before Jun- uary 1, 1995 H.L.C. C5. Source of Additional Federal Funds Remaining Federal funds would come from previous general revenues dedicated to medicaid and from other sources (to be specified). F:\FHBC\UNIMED 71 H.L.C. UNIVERSAL MEDICAL CARE (UNIMED) ACT OF 1992 Financing [title VI]-Medicare Eligibility Expansion Issue/Topic Policy Notes F:\FHBC\UNIMED D. Medicare Program Eligibility Expansion Increase cup on III part of FICA & SECA tax to extent necessary to fund expenses for expanded eligibility. 72 H.L.C. UNIVERSAL MEDICAL CARE (UNIMED) ACT OF 1992 Financing [title VI]-Low-Income Assistance Issue/Topic Policy Notes F:\FHBC\UNIMED E. Low-Income Assistance (covering low-income Addition to income tax at flut rate of 1/5 of the employees, children, and others) MediWorkers National Premium Percentage (MNPP). However, wages, self-employment income and other in- come, to the extent a UniMed premium has been com- puted based on such income, would not be subject to this additional tax. 73 H.L.C. UNIVERSAL MEDICAL CARE (UNIMED) ACT OF 1992 Overall Administration [title VII] Issue/Topic Policy Notes FAFHBC\UNIMED A. Health Benefits Administration (HBA); basic Health Benefits Administration (HBA), headed by 15- structure member board appointed from private sector by Presi- dent with Senate confirmation, 6-year staggered terms. (Board also includes 2 additional members solely for pur- poBeB of administering the ERP process. See, under title I, H1. (c)(1) -2.) Would be established by not later than March 1, 1993. Paid at Executive Level 11. No more than 8 of same political party. 3 appointed from each of the following: labor; employers; medical community, in- surance community, consumer representatives. Chair elected by board. Will include: -the Federal Health Benefits Equalization Corporation (FHBEC) (see below); -the Group Health Plan Review Board (GHPRB) (see below); 74 -an Office of Special Counsel (SC) (see below); -an Early Resolution Program Office, headed by Chief Facilitator (see below); -an Office of Executive Director, appointed by and serving at pleasure of the board; a MediWorkers Office; a MediKids Office; and MediWrap Office. HBA will also include 4 Advisory Committees with re- gard to discrete coverage issues. HBA will administer the entire program, through the Executive Director, except for independent functions del- egated by statute to FHBEC, SC, and GHPRB. HBA will have budgetary independence (similar to independence in recent legislation for independent SSA) H.L.C. B. Federal Health Benefits Equalization Corpora- Corporate entity established in HBA by not later than tion (FHBEC) June 1, 1993. Board of Directors consists of the HBA board. Sole and exclusive authority over- -assessment and collection from plans (including self- F:\FHBC\UNIMED insured employers) of equalization premiums; -distribution of equalization rebutes to plans (includ. ing self-insured employers) -Has structure und powers similar to those of Pension Benefit Guaranty Corporation (PBGC) under existing law. Most administrative and support personnel and services will be provided by HBA. -Receipts and disbursements will be off-budget (viz., non-budget). C. Office of Special Counsel -Purpose is to receive, process, and (if appropriate) prosecute complaints of violations of Act or plan filed by participants or beneficiaries. [mode] of Immigration dis- crimination enforcement] -Appointed by President with Senate confirmation for 75 6-year term. Removed only for cause. -Recommends Early Resolution Program before pro- ceeding to administrative review in procecutorial fushion before GHPRB or rejecting the case and returning a "right to proceed" letter to the complainant. D. Early Resolution Program (ERP) Office Headed by Director appointed by HBA. Staff will devel- op program procedures, conduct case intake, maintain roster of "facilitators", coordinate facilitator selection process, provide meeting sites, maintain records, and provide facilitators with legal assistance and administra- live support staff. E. Group Health Plan Review Board (GHPRB) 9 members appointed by President with Senate confir- mation. President designates Chair. 6-year, staggered terms. Removed only for cause. Appoints ALJ's to hear complaints of participants and beneficiaries not resolved through ERP. Governed by APA. (Similar to OSHRC, 29 U.S.C. 661) H.L.C. February 20. 1992 (12:50 p.m.) UNIVERSAL MEDICAL CARE (UNIMED) ACT OF 1992 Medicare Revisions [title VIII] Issue/Topic Policy Notes F:\FHBC\UNIMED A. REDUCTION IN AGE OF MEDICARE ELIGIBIL- Reduce, as of January 1, 1995, age of initial eligibility to ITY 60. Provide for a transitional enrollment period, beginning July 1, 1994, during which individuals who will be be- tween 60 and 65 as of January 1, 1995, could enroll. In the future, there would have to be established special enrollment process to take into account the fact that most individuals at age 60 are not receiving Social Secu- rity benefits. 76 H.L.C. UNIVERSAL MEDICAL CARE (UNIMED) ACT OF 1992 Miscellaneous Provisions [title IX] Issue/Topic Policy Notes ".\FHBC\UNIMED UNIMED REPEAL OF COBRA CONTINUATION PROVI- Effective January 1, 1995, repeal the COBRA continu- [ONS ation requirements contained in ERISA, the IRC, and the PHSA. GRANT PROGRAM FOR EXPANSION OF FED- Provide un authorization of appropriations of an addi- RALLY QUALIFIED HEALTH CENTERS tional $400, $800, $1200, $1600, and $1,600 millions in fiscal years 1993 through 1997 for expansion of services to medically underserved individuals by Federally quali- fied health centers. 77 H.L.C. Bush V. Clinton Health Plans Access Bush Clinton Comment Goal Universal access to Universal access to health insurance health insurance Approach Incentives Mandates (taxes by Clinton plan means job another name) loss; slower rate of small business creation. Methods - Tax credits and tax deductions - Employers must provide health - Clinton says employers will be insurance to their employees ("play eligible for tax subsidies; says - Reforms of the health insurance or play") nothing about what they would be. market to make insurance more affordable. - Endorses similar market reforms - While Clinton offers few details, he endorses proposals similar to the President's; both "take on the insurance companies." Paying for the plan - We have identified sufficient - Cost controls from "global - Clinton offers no timetable for savings to meet the $100 billion, budgeting" would pay for increased implementing access provision nor five year implementation cost coverage. any details on the size, scale, or without raising taxes. composition of his financing package. Small business - Guarantee that all small - Mandate that employers provide - Mandates would make it more employers can get coverage; rate health care; provide "tax credits to difficult for small businesses to bands to make sure prices are protect businesses." form; increased labor costs would - Of 34 million without health affordable. send more jobs overseas. insurance; 25 million work for or are family of workers in - Help for low income workers in firms with fewer than 25 small firms through tax credits. employees. 1 Middle class - Credit and deduction available for - No help for middle-income all families with incomes up to families with low employer $80,000. contributions (the 44 million who - The deductible amount is $3,750 would be helped under the Bush for families and $1,250 for plan.) individuals, minus the value of - Where employers are hit by the employer contributions. new mandate to buy insurance, - 44 million middle-income employees would be required to individuals would receive some pay a share -- all dollars flowing help. from employees' pockets. Insurance security - Guarantee that workers can move - Appears similar; no details from job to job offering health provided. insurance without losing coverage because of pre-existing conditions (e.g., already pregnant, having cancer.) Choice of benefits - State laws that mandate benefits - A new "National Health Care - Clinton plan could raise costs for would be pre-empted. Board" will prescribe minimum employees by requiring them to benefits that all employers must buy more insurance than they do provide. already. - Clinton plan will create a floor under the cost of plans all employers must provide. Choice of doctor - Health insurance - Rhetoric of "allow consumers to - Eliminating the "pay" option of credits/deduction available for choose where to receive care." "pay or play" in the Clinton plan insurance plans that provide care as defuses charge that Clinton consumers want: through private approach leads to nationalized physicians; HMOs, etc. plan/loss of consumer choice. 2 People not working - Eligible for credit/deduction. - Private coverage for non-workers - Bush plan is for a five year and their families would be guaranteed private phase in; Clinton plan may never - Credit/deduction would be phased insurance coverage that would be phase in. in over 5 years. - 10 million of the uninsured arranged through government run do not work. purchasing cooperatives (similar to - Both plans would leave some - Those who use credit are Bush-proposed "HINs.") uninsured; those uninsured would guaranteed coverage through at be those who choose not to buy least one plan the state must make - Non-workers will pay a sliding insurance. available through a private insurer. scale premium based on income. - Those now receiving Medicaid would be transferred to this plan. - Savings from cost controls would pay for expansions in coverage; no timetable provided. 3 Controlling Costs Bush Clinton Comment Goal Highest quality at the Reduce costs no matter lowest cost what the quality. Approach Deliver care more "Global budget;" Clinton plan calls for efficiently; end causes of arbitrary limits on how unprecedented waste and abuse much can be spent on government involvement health care. Annual in health resource increase limited to rate of allocation decisions. increases in wages. Role of government Run government A National Health Care "Global budgets" only programs more Board would decide total squeeze the health cost efficiently; address forces health spending and set balloon; squeezing that drive costs -- ceilings for each state. through price fixing will malpractice, market lead to shortages (thus failure, etc. rationing) and lower levels of new No price regulation. States will decide prices technology. for all health services. Malpractice Requirement for arbitration Wants to make alternative to before going to court; if you then courts available; no requirement to go to court and don't do better by use alternatives. more than 10 percent, you are No support for tort reform. liable for the other side's attorney fees. Tort reform. 4 Administrative savings Use "electronic cards" and Similar. Clinton borrows from the Bush automation to reduce the amount of list. paperwork patients and doctors complete. Introduce a single, standardized claims form. Prescription drugs No proposal. End certain tax preferences for pharmaceutical companies that raise prices faster than the rate of inflation. Information for consumers Require states to make No proposal. information about the cost of health plans and providers (hospitals, etc.) available for comparison shopping. 5 Bush V. Clinton Health Plans Access Bush Clinton Comment Universal access to Universal access to Hea 1th us health insurance health insurance for Aarhon Incentives Mandates (taxes by Clinton plan means job another name) loss; slower rate of small business creation. Methods - Tax credits and tax deductions - Employers must provide health - Clinton says employers will be insurance to their employees ("play eligible for tax subsidies; says - Reforms of the health insurance or play") nothing about what they would be. market to make insurance more affordable. - Endorses similar market reforms - While Clinton offers few details, he endorses proposals similar to the President's; both "take on the insurance companies." Paying for the plan - We have identified sufficient - Cost controls from "global - Clinton offers no timetable for savings to meet the $100 billion, budgeting" would pay for increased implementing access provision nor five year implementation cost coverage. any details on the size, scale, or without raising taxes. composition of his financing package. Small business - Guarantee that all small - Mandate that employers provide - Mandates would make it more employers can get coverage; rate health care; provide "tax credits to difficult for small businesses to bands to make sure prices are protect businesses." form; increased labor costs would - Of 34 million without health affordable. send more jobs overseas. insurance; 25 million work for or are family of workers in - Help for low income workers in firms with fewer than 25 small firms through tax credits. employees. 1 Middle class - Credit and deduction available for - No help for middle-income all families with incomes up to families with low employer $80,000. contributions (the 44 million who - The deductible amount is $3,750 would be helped under the Bush for families and $1,250 for plan.) individuals, minus the value of - Where employers are hit by the employer contributions. new mandate to buy insurance, - 44 million middle-income employees would be required to individuals would receive some pay a share -- all dollars flowing help. from employees' pockets. Insurance security - Guarantee that workers can move - Appears similar; no details from job to job offering health provided. insurance without losing coverage because of pre-existing conditions (e.g., already pregnant, having cancer.) Choice of benefits - State laws that mandate benefits - A new "National Health Care - Clinton plan could raise costs for would be pre-empted. Board" will prescribe minimum employees by requiring them to benefits that all employers must buy more insurance than they do provide. already. - Clinton plan will create a floor under the cost of plans all employers must provide. Choice of doctor - Health insurance - Rhetoric of "allow consumers to - Eliminating the "pay" option of credits/deduction available for choose where to receive care." "pay or play" in the Clinton plan insurance plans that provide care as defuses charge that Clinton consumers want: through private approach leads to nationalized physicians; HMOs, etc. plan/loss of consumer choice. 2 People not working - Eligible for credit/deduction. - Private coverage for non-workers - Bush plan is for a five year and their families would be guaranteed private phase in; Clinton plan may never - Credit/deduction would be phased insurance coverage that would be phase in. in over 5 years. arranged through government run - 10 million of the uninsured purchasing cooperatives (similar to - Both plans would leave some do not work. - Those who use credit are Bush-proposed "HINs.") uninsured; those uninsured would guaranteed coverage through at be those who choose not to buy least one plan the state must make - Non-workers will pay a sliding insurance. available through a private insurer. scale premium based on income. - Those now receiving Medicaid would be transferred to this plan. - Savings from cost controls would pay for expansions in coverage; no timetable provided. 3 Controlling Costs Bush Clinton Comment Goal Highest quality at the Reduce costs no matter lowest cost what the quality. Approach Deliver care more "Global budget;" Clinton plan calls for efficiently; end causes of arbitrary limits on how unprecedented waste and abuse much can be spent on government involvement health care. Annual in health resource increase limited to rate of allocation decisions. increases in wages. Role of government Run government A National Health Care "Global budgets" only programs more Board would decide total squeeze the health cost efficiently; address forces health spending and set balloon; squeezing that drive costs -- ceilings for each state. through price fixing will malpractice, market lead to shortages (thus failure, etc. rationing) and lower levels of new No price regulation. States will decide prices technology. for all health services. Malpractice Requirement for arbitration Wants to make alternative to before going to court; if you then courts available; no requirement to go to court and don't do better by use alternatives. more than 10 percent, you are No support for tort reform. liable for the other side's attorney fees. Tort reform. 4 Administrative savings Use "electronic cards" and Similar. Clinton borrows from the Bush automation to reduce the amount of list. paperwork patients and doctors complete. Introduce a single, standardized claims form. Prescription drugs No proposal. End certain tax preferences for pharmaceutical companies that raise prices faster than the rate of inflation. Information for consumers Require states to make No proposal. information about the cost of health plans and providers (hospitals, etc.) available for comparison shopping. 5 H.Kuatner EXECUTIVE OFFICE OF THE PRESIDENT COUNCIL OF ECONOMIC ADVISERS WASHINGTON, D.C. 20500 July 24, 1992 THE CHAIRMAN MEMORANDUM FOR: SAM SKINNER NICK BRADY DICK DARMAN CLAYTON YEUTTER ROGER PORTER FROM: MICHAEL J. BOSKINM SUBJECT: Deficit Reduction/Tax Increase in the Clinton Plan How large a tax increase would be needed to reduce the projected 1996 deficit by half while funding all the spending that Clinton proposes in his economic plan? The list of spending cuts must be pruned of proposals that simply are not feasible or whose savings are clearly imaginary. These include: -- unspecified "administrative savings" -- "reform Defense Department inventory system" -- "RTC management reform" -- "streamline USDA field offices" - o Total savings from the Clinton plan (excluding the deleted items) are $31.04 billion in 1996 using his optimistic estimates for the following categories (many of which may also be unfeasible). Defense cuts 16.50 Intelligence cuts 1.50 100,000 employees 4.50 Cut White House staff 0.01 Debt financing reform 2.00 Cut Congressional staff 0.10 * Line-item veto 2.00 Energy conservation 0.85 Reduce university overhead 0.82 Special purpose HUD grants 0.13 Index nuclear waste fees 0.08 Consolidate foreign broadcasting 0.27 Freeze consultant spending 0.21 Consolidate social service 0.27 Raise Medicare-B costs (technically, a revenue increase) 1.80 31.04 * We have already given him credit for these claimed budgetary savings. The $2 billion associated with line-item veto means he is either double-counting, or there are $2 billion more in unspecified cuts. 2 o Total spending increases under Clinton's plan are $134.1 billion in 1996. -- The plan involves spending increases of $64.1 billion, not including Clinton's health insurance proposal. -- Clinton's health insurance proposal (disguised play or pay) is estimated to cost $70 billion per year by 1996. It is not clear what portion of this cost will be paid with the payroll tax mentioned in the plan. o Using (heresy) CBO figures, yields a deficit of $222 billion in 1996 (excluding deposit insurance). To cut that in half while enacting his plan, Clinton must generate (222/2 + 134.1 - 31.04) = $214.06 billion in revenue. -- If that amount is to be raised through increases in the personal income tax, Clinton will need to raise Federal income tax revenues by about 34 percent. - This fraction is based on CBO's projection for income tax revenue of $634 billion in 1996. - Actual tax rates would need to be increased by a larger fraction to generate the needed revenue (since taxable income is a decreasing function of the tax rate). Clinton's plan includes the following tax increases (billions of dollars in 1996, as claimed by Clinton): - "increase rates on top 2%, raise AMT, surtax on millionaires:" = 23.0 - "prevent tax fraud on unearned income for the wealthy:" = 2.3 - "limit corporate deductions at $1 million for CEOs:" = 0.4 - "end incentives for opening plants overseas:" = 0.4 - "prevent tax avoidance by foreign corporations:" = 13.5 - "increased fines and taxes for corporate polluters:" = 2.9 3 - "eliminate tax deduction for lobbying expenses:" = 0.1 - a payroll tax as part of the health care proposal, without any figure given on that tax's revenues - The total 1996 claimed revenue from the above items (excluding the payroll tax) is $42.6 billion -- Thus, even granting him these overly optimistic revenues, he still is $172 billion short, and would have to raise everyone's federal income taxes by over 25 percent.