| The CBEBT is generally subject to the provisions of the Patient Protection and Affordable Care Act (the “ACA”). Accordingly, to the extent that ACA would legally require the CBEBT to provide a particular benefit, the CBEBT will do so, unless providing the benefit would conflict with the doctrine or tenets of the Roman Catholic Church.
Minimum Essential Coverage
Under the ACA, plans must meet Minimum Essential Coverage Standards to be considered a Qualified Health Plan. Minimum Essential Coverage is met if a plan meets a Minimum Actuarial Value and covers the 10 Essential Health Benefits as outlined by the Affordable Care Act.
Actuarial Value is defined as the proportion of covered medical expenses a plan is expected to pay on average for a standard population, as compared to the percentage the plan participant is expected to pay via deductibles, coinsurance, copayments and other out-of-pocket expenses. An Actuarial Minimum Value of 60% or more means the plan pays 60% or more of the total average costs for covered benefits. All plans offered under the CBEBT have been certified by a MAAA Actuary (link to letter) to meet the ACA Minimum Value.
Essential Health Benefits include the following: Outpatient Care, Emergency Room Services, Inpatient Hospitalization, Maternity & Newborn Coverage, Mental Health & Substance Abuse Services, Prescription Drug Coverage, Rehabilitative Services, Lab Tests, Preventive Services (including counseling, screenings and vaccines), and routine Pediatric Dental and Vision screenings. All programs offered under the CBEBT offer coverage in these 10 Essential Health Benefit categories, without any annual or lifetime dollar limits. For more information on covered benefits, please refer to your Summary of Benefits and Coverage (SBC) and your Benefit Plan Document.
Section 1557 (Nondiscrimination)
ACA Section 1557 provides that an individual shall not be excluded from participation in, be denied the benefits of, or be subjected to discrimination on the grounds prohibited under Title VI of the Civil Rights Act of 1964 (race, color, national origin), Title IX of the Education Amendments of 1972 (sex), the Age Discrimination Act of 1975 (age), or Section 504 of the Rehabilitation Act of 1973 (disability), under any health program or activity, any part of which is receiving federal financial assistance, from the U.S. Department of Health and Human Services (HHS), such as Medicare or Medicaid funds.
On July 18, 2016, HHS published a final rule implementing Section 1557 requiring health plans that receive HHS funds to make necessary changes comply with ACA Section 1557 on the first day of the plan year beginning on or after January 1, 2017. Only health programs or activities that receive financial assistance from HHS – called “Covered Entities” – are subject to the rule. The CBEBT does not receive any HHS funding, and therefore, is not subject to Section 1557. However, an Employer participating in the CBEBT could be a Covered Entity itself by virtue of receiving HHS funds (e.g., a hospital receiving Medicare or Medicaid funds) and would need to seek its own counsel as to how to comply with Section 1557. |