Five Important Changes for Group Health Insurance Clients in 2022
The new year brings with it changes for employers, employees, and group health insurance. Here’s information you may want to share with your clients.
2022 Health Insurance Changes
1: Increased FSA Contribution Limits
The Internal Revenue Service (IRS) previously published the increased limits for contributions to Health Flexible Spending Accounts (Health FSAs) in 2022. The new limits are:
Health Flexible Spending Accounts (Health FSAs)
|2022 Maximum Salary
|Change from 2021|
Dependent Care Flexible Spending Accounts (DC-FSAs)
|2022 Maximum Salary
|Change from 2021|
$2,500 Married, Filing Separately
|In 2021, as part of the American Rescue Plan (ARP) Act, Dependent Care FSA contributions were expanded to $10,500 for the 2021 plan year only; however, the pre-ARP Act limit was $5,000.|
2: HDHP and HSA Limit Changes
High Deductible Health Plan (HDHP) maximum out-of-pocket amounts and Health Savings Account (HSA) contributions have also been adjusted for 2022.
|Contribution and Out-of-Pocket Limits
for HSAs and HDHPs
|HSA contribution limit (employer + employee)||Self-only: $3,650
|HDHP maximum out-of-pocket amounts (deductibles, copayments, and other amounts – but not premiums)||Self-only: $7,050
|HDHP minimum deductibles||Self-only: $1,400
|No change for either Self-only or Family|
For your clients’ employees who are age 55 and older, the HSA catch-up contribution is the same last year: $1,000.
3: “No Surprises Act”
You probably know the “No Surprises Act,” passed by Congress as part of a year-end 2020 omnibus spending bill, took effect this month. The law limits surprise medical bills for individuals with health insurance who receive inadvertent out-of-network care in emergency treatment situations. It also limits bills from out-of-network providers who provide services at in-network facilities.
For example, if an insured patient receives care for an accident and is unable to furnish information about where treatment should be sought, his/her/their transport could be to an out-of-network emergency room, which could result in unanticipated charges.
A second example is if a patient receives care at an in-network provider, but from a specialist like an anesthesiologist who is from outside of the insured person’s provider network.
In both of these situations, the patients would incur surprise charges, although not due to any action taken by them.
Under the “No Surprises Act,” health plans must offer emergency care without preauthorization, without regard to in-network or out-of-network status, with no requirements that would be more restrictive than for in-network services, and with cost sharing for out-of-network providers that is no greater than if providers were in-network.
Non-emergency services cost sharing for out-of-network services cannot be greater than cost sharing for in-network services.
There is some discussion ongoing about tweaks to the No Surprises Act; however, members of Congress have not worked out anything thus far.
4: New Out-of-Pocket Cap
The health coverage maximum out-of-pocket limit for in-network care for essential health benefits is $8,700 for a single person in 2022. For a family, the limit is $17,400. These limits will not apply if your client has a “grandmothered” or “grandfathered” plan or a fixed indemnity health plan.
5: Compensation Disclosure
The Consolidated Appropriations Act signed into law in 2020, affects you and those you serve. It requires health insurance professionals to disclose their commissions to clients, in writing, in advance of a sale. The law applies to contracts entered into on or after December 27, 2021, if you reasonably expect to earn more than $1,000 in “direct compensation” and/or more than $250 in “indirect compensation” from the health plan or insurance carrier.
The disclosure generally applies to all types of health insurance – across all market segments (Small Group, Large Group, IFP, self-funded plans, and fully funded (traditional) plans, FSAs, HRAs, etc.). Brokers must keep disclosures accurate and up to date, with any changes in commission disclosed to clients within 60 days.
Word & Brown Director of Education and Market Development Paul Roberts has authored an update of his November 2021 Compliance column concerning the new CAA Disclosure; you can read the Federal Broker Disclosure Requirements in the Group Market – Update in our Newsroom.
Paul’s new column also includes links to Word & Brown resources on commissions offered on California and Nevada products as well as a customizable disclosure template for your use.
California Senate Bill 280 removes discriminatory practices in the Large Group Health Insurance market by now mandating coverage for medically necessary basic care services. It includes women’s reproductive services, HIV medications, cancer treatments, obesity care, and organ transplantation.
While not effective until next year, and only affecting the Individual Health marketplace, California Assembly Bill 570 will expand health care access for older adults. Under the legislation, adult children who have individual and family health coverage can add dependent parents or stepparents to their policies. If you’re in the IFP market, this could affect clients during their Fall 2022 open enrollment period (for coverage starting in 2023). The California Department of Insurance and carriers doing business in California are expected to release more information in coming months.
To stay up to date on everything that is happening in the health insurance industry, be sure to visit the Word & Brown Newsroom, where we regularly post carrier, health care, and related news.
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