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Now that the 2004 Open Enrollment process is over
for most employers, it is time to look toward the future. Will HSAs be
in yours?
For an individual to participate in an HSA he must
be enrolled in a qualified high-deductible health plan (“HDHP”). An HDHP
must have a deductible of at least $1,000 individual or $2,000 family
and an out-of-pocket limit, including deductibles and coinsurance, of
not more than $5,000 individual or $10,000 family. He must also not
participate in any other health plan, other than certain “permitted
coverage”, including dental, vision and long term care. The HDHP can
also have first dollar preventive care and higher out-of-network limits.
For eligible individuals under 55, the maximum
annual contribution is limited to the lesser of the annual deductible or
$2,600 individual, $5,150 family in 2004 and adjusted for inflation in
future years. It appears that a plan with a $2,500 deductible and
$2,500 coinsurance maximum would allow for faster accumulation of
contributions into the HSA compared to a $1,000 deductible with a $4,000
coinsurance maximum.
At least two things need to happen before we can
really begin evaluating how HSAs might fit into our future benefit
options. First, the Internal Revenue Service and the Department of Labor
must issue additional guidance. That is expected soon. Two of the key
issues they must address are what first dollar preventative care
benefits are permitted in an HDHP and how must the HSA be trusteed and
adjudicated.
Secondly, insurance companies must offer qualified
HDHP insurance products. A few companies, like Golden Rule and Fortis,
have begun offering individual products qualifying as HDHPs and we
understand most large insurers will be offering group plans soon. The
pricing of these products will be critical to the success of HSAs. It
also seems critical that the products include the negotiated discounts
that the large insurers have with medical providers.
It will be interesting to see if HRAs and other
“consumer driven health plan” trends are part of a solution to the
double digit health care inflation crisis, or just a shift of the burden
from employers to employees. We will continue to monitor the trends in
future articles.
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