Author Archives: Reeve Conover

Responding to Pay or Play Mandate Letters

If you have gotten, or may receive a non-compliance pay or play letter from the IRS, this important article can help you through the process.

Published in Employee Benefit Adviser on July 6, click here for full article.

These letters can range from the employer paying the penalty outright, paying a portion of the penalties, none of the penalties, attend an IRS hearing disputing the penalties or pursue further legal action in federal court.  To give the accused a chance to plead their case, Letter 226-J gives employers the opportunity to refute the assessed penalty amount by filing Form 14764. Depending on the applicable large employer’s response the IRS has begun to issue one of five versions of IRS Letter 227 as a response to the action the employer chooses to take on Letter 226-J.


Medicare To Provide More Benefits For Chronically Ill

From Allwell Centene:”

In what the New York Times (6/24, Pear, Subscription Publication) calls “a rare instance of bipartisan cooperation on a major policy initiative,” the Trump Administration and Congress are “revamping Medicare to provide extra benefits to people with multiple chronic illnesses, a significant departure from the program’s traditional focus that aims to create a new model of care for millions of older Americans.” The changes, says the Times, “tackle a vexing and costly problem in American health care: how to deal with long-term illnesses that can build on one another, and the social factors outside the reach of traditional medicine that can contribute to them, like nutrition, transportation and housing.” The additional benefits “can include social and medical services, home improvements like wheelchair ramps, transportation to doctor’s offices and home delivery of hot meals.”

Risk Adjustment Suspension reversed by Trump

July 27-  In a reversal, the Trump Administration will resume risk adjusted payments to Health Insurers.  A few weeks ago we reported that the Administration was suspending payments to carriers under the risk adjustment payment program under the Affordable Care Act in the Individual and Small Group Markets. They now said they will restart the program that pays billions to insurers to stabilize health insurance markets.



3 recent articles covering the Trump administration’s decision to suspend Risk Adjustment payments to insurers which were intended to help insurers cover costs for sicker patients.  This will cause insurers to rethink and possibly refile their filed rates for Individual and Small Group plans for 2019.  Insurers were due to receive upwards of $10 billion dollars to offset high claimants in these markets.  This will certainly cause some turmoil and cause for debate and discussion.  In New York, Oxford has benefitted greatly from these payments, last year taking in around $250 million in payments from other carriers in New York state.  Risk adjustment payments are what also took down CareConnect, having to in essence pay over $100 million dollars to Oxford.  The risk adjustment payment programs are certainly a flawed methodology created by the previous administration, what the solution is.. no one is really certain of that, but this will certainly have some reaction to it and cause carriers to reconsider their intended filings for 2019.

We will keep you posted of new developments.

Massachusetts raises minimum wage and enacts family leave

Massachusetts now joins California, New York and Washington, D.C. as the only states to have both a $15 minimum wage and mandatory paid family and medical leave.  It also eliminates some mandatory overtime rules, and gradually phases in over 5 years.  If you are a Massachusetts-based employer or have employees there, this is a must read.  Click here.

Why health care sharing memberships continue to grow

Great article in Fox Business about how these plans work and why they are popular.  on the plus side, they are a lot less expensive.  on the negative side- they are not insurance and there is no guarantee of payment.  For the full article, click here.

October 2018
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Reeve Conover is a Registered Representative. Securities offered through Cambridge Investment Research, Inc., a Broker/dealer member FINRA/SPIC. Cambridge and Conover Consulting are not affiliated. Licensed in SC, NC, NY, CT, NJ, and CA. - SIPC - Brokercheck