Going Beyond Simple Compliance Requires Strategic Action

Since the start of 2022, Jack Towarnicky, member of aequum health, has joined benefits industry colleagues in presenting on a variety of topics as part of Humaculture’s Hidden Opportunities, Strategic Compliance Series. This five-part monthly webinar series offers guidance to plan sponsors and third-party claims administrators on how to strategically respond to the No Surprises Act (NSA) and Transparency in Coverage compliance requirements to gain a competitive advantage while minimizing cost and complexity.

Plan sponsors should take strategic action – changes that go far beyond simple compliance –
to ensure that their employer-sponsored, self-insured plans incorporate the most effective strategies available today for the “health and wealth” of their participants. These strategies include effectively designed acquisition cost-based pharmacy pricing, HSA-capable coverage, along with reference-based pricing, adequate participant protections against balance billing, participant advocacy and litigation support.

January: Surpassing Mere Compliance – Including Reference Based Pricing
On January 1, provisions of the NSA took effect to protect health plan participants from certain surprise medical bills for emergency services and care received from out-of-network providers at in-network facilities. Plan sponsors who stop with simple NSA compliance will experience an increase in employer-paid medical expenses. Price transparency is expected to add to medical cost inflation by prompting both in-network and out of network providers to increase charges. The best response is through an approach that is both strategic and compliance oriented. A dual approach will minimize the compliance challenge, reduce the cost of coverage for both the employer and employees, and improve both the perceived and actual value of health coverage. January’s session reviewed the strategic opportunity Reference Based Pricing (RBP) offers. When it comes to these new requirements, RBP may be your plan’s MVP – Most Valuable Provision.

February: Preserving the Harvest…Leveraging HSAs Hidden Opportunities: Transparency in Coverage Rules
Many workers today are “financially fragile” – unprepared for everyday expenses, let alone out-of-pocket medical expenses. Most workers have no savings earmarked for regular medical cost sharing – copayments, deductibles, coinsurance, etc. That is, for most Americans, regular out-of-pocket medical expenses are often “unexpected.” So, even though the NSA is now in place to protect patients from “surprise” bills, it’s no surprise how unprepared many Americans are for their health plan’s point of purchase cost sharing. Done right, an HSA strategy will prepare participants for out-of-pocket cost-sharing. And, because HSAs assets can be invested and because there is no forfeiture, no “use or loss”, HSAs have evolved to become part of a “health and wealth” rewards strategy.

March: A “Dope” Response to Pharmacy Transparency
The NSA requires plans to offer participants health care price comparisons for certain prescription drugs. Beginning July 1, 2022, most group health plan and issuers of group or individual health insurance will begin posting pricing information. Health plan price transparency might help healthcare consumers know the true cost of a covered service before receiving care. However, new pharmacy transparency law will not increase transparency as it will generally require reporting of information already known to plan sponsors.  The new requirements will increase costs, administration, and litigation risk. Acquisition Cost Based Pharmacy Pricing and Behavioral Design and Messaging are strategic actions to take in addition to simple compliance, to avoid what can be avoided, provide true transparency with pharmacy benefits, and empower consumers to make better, more clinically appropriate decisions.

Next Webinars

Join Jack and others for the last two sessions in the five-part series. Next up is Hidden Opportunities: Mental Health Parity – A Lucid Approach, on Thursday, April 21, at 1 p.m. EST. The fifth and final session is scheduled for May 19, at 1 p.m. EST titled: Pest Management, Minimizing Plan Losses Through Fee Disclosure. Register here.