Tag Archives: retiree drug subsidy

Regulatory roundup

More healthcare-related regulatory news for plan sponsors, including links to detailed information.

ACA Information Returns Submission (AIR) guide updated
The Internal Revenue Service (IRS) has released its “ACA Information Returns (AIR) Submission Composition and Reference Guide.” The guide was updated as of March 16, 2018. The purpose of this document is to provide guidance to all types of external transmitters about composing and successfully transmitting compliant submissions to IRS.

To download the guide, click here.

RDS to start accepting Medicare Beneficiary Identifier files
The Retiree Drug Subsidy (RDS) Center of the Centers for Medicare and Medicaid Services (CMS) will begin accepting the Medicare Beneficiary Identifier (MBI) in retiree files in accordance with CMS’s new Medicare Card Project, beginning April 1, 2018. Healthcare plan sponsors should review the RDS program website’s “New Medicare Card Project” page for helpful guidance on this initiative and how it impacts the RDS program.

For more information, click here.

The importance of evaluating RDS and EGWP trends to optimize plan value

Financial dynamics and an evolving regulatory environment in the group retiree pharmacy benefits market continue to influence the relative values of Employer Group Waiver Plans (EGWPs) and Retiree Drug Subsidy (RDS) plans. Plan sponsors should periodically monitor and evaluate emerging trends in these programs to optimize plan value in this still-changing market.

Last summer, for example, the Centers for Medicare and Medicaid Services (CMS) announced a large decrease in the monthly direct subsidy revenue to EGWPs. Additionally, the Medicare Payment Advisory Commission (MedPAC) recently proposed changes to the Medicare program with major implications for EGWP costs.

Figure 1 summarizes key recent and proposed market and regulatory dynamics that are already impacting the relative values of EGWPs and RDS plans—and which could potentially influence further shifts in these values.

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Retiree drug subsidies taxable under PPACA

The Retiree Drug Subsidy Program (RDS) was created to enable employers to assist Medicare-eligible retirees in acquiring more cost-effective drug coverage. Under the Patient Protection and Affordable Care Act (PPACA), employers will now be taxed on government subsidies associated with the program.

Troy Filipek provides perspective on the subsidy taxation in this BenefitsPro article. Here is an excerpt:

“The big change for 2013 with the RDS program is that in the past, from 2006 forward, the allowance that these employers receive from the government for the subsidies used to be non-taxable income,” Filipek says. “That has changed since the enactment of the [PPACA].”

Now, Filipek explains, the money that employers receive from the government for these subsidies is subject to taxation.

“It’s a pretty big change,” he says. “A lot of employers have already felt the impact of it because once the law passed, based on the accounting standards, you had to recognize the future impact of that in your financial statements.”
Substantial adjustments have been taken in the form of reflections of these soon-to-be taxed subsidies. “Starting in 2013, it will be a practical effect that these moneys are going to be taxed,” Filipek says.

He notes that a lot of brokers, advisors and even employers are currently in the process of reevaluating their options for offering retirees prescription drug coverage. As far as what steps are necessary to take in order to be prepared for the coming year’s changes, Filipek feels it’s important for employers and their advisors to simply understand that there are a variety of choices available.

Options include continuing coverage and working with the newly taxed subsidies or dropping coverage and allowing retirees to enroll in individual part D plans. Additionally, Filipek says, employers can maintain group coverage and work with a pharmaceutical benefit manager or health plan in the Part D program to develop a custom benefits package through a Part D Employer Group Waiver Plan plus secondary wrap plan design, which are plan options gaining traction in the marketplace.

Regardless of what decision is made, it’s imperative that both brokers and HR professionals “make sure it’s seamless for the retiree and easy for them to understand,” Filipek says.

“It’s important to communicate with the retirees because these are not people who are coming into the workplace every day where it’s easier to communicate with them. You have to find ways for outreach to them and their spouses.”