Health care reform: Age 26 dependents—FAQs

This is a template for answers to frequently asked questions your employees may have about health care reform. To use these FAQs, you should review in detail and edit carefully to be consistent with your benefit plans, the tone of your employee communication and your benefits strategy. You may also want your health care consultants and attorneys to review your answers before you make them widely available. Also please see our common sense caveat below.

Last week, we recommended talking points for employees on new dependent eligibility rules. If you haven’t already, arm your call center or HR generalists with commonly asked questions about how your company will implement the new law—early or as legislated. Feel free to use these sample questions.

Note: Be sure to customize questions based on the start and end of your plan year.

Q. The news says that many health carriers—including ours—are already covering older dependents. Why can’t I add my child now?

A. The provision takes effect for us [insert plan year start date], the start of our plan year. Making any change to our plans takes careful planning. Congress understands that this new provision requires administrative, budget and communication considerations. That’s why the law affords employers advance notice of the provision and time to comply with it.

The law encompasses provisions that impact employer-sponsored health plans, like ours, as well as provisions that impact the individual health plans, sponsored by health carriers. Many of the headlines you see relate to health carriers and their business decision to allow individual policy customers to add their adult children onto their plan.

Watch for our enrollment materials this fall for action steps to enroll your child for coverage effective[insert coverage effective date].

Q. The law was signed in March 2010. When will I be able to add my child(ren) to my plan?

[Adjust this for when your plan year begins and ends.] A. This component of health care reform doesn’t take effect immediately because Congress understands that it takes time for the administrative and budget planning process to occur in companies. So, this provision of the law is tied to an employer’s plan year—ours being [insert your plan year]. Specifically, the law states that this provision becomes effective at the start of the plan year after September 23, 2010. And for us, that next plan year is [insert start of plan year].

We know having access to benefits coverage for your children is very important. You may have options to secure stop-gap coverage for children who are graduating from college or aging out of dependent coverage on a family policy. Check with your medical plan to start.

[Include this section if your team is evaluating whether you can comply earlier than required.] Currently, our Benefits team is researching and assessing how this affects each plan we offer and whether it’s feasible to offer this coverage before the required date.

We will keep you informed of this and other impacts of health care reform as soon as we have more details.

Q. My daughter is 23 and on my plan, but she’s scheduled to lose coverage soon. How can I keep her on my health insurance?

A. Your daughter will become eligible again [insert the start of your plan year]. If she ages out of our plan when she will no longer be a full-time student, there are a few actions she can take to maintain insurance coverage.

1. First, check with your medical plan provider. Many health insurance companies have volunteered to provide coverage for young adults losing coverage as a result of graduating from college or aging out of dependent coverage on a family policy. This stop-gap coverage, in many cases, is available now.
2. Second, watch for COBRA enrollment. This scenario is why COBRA was created, so why not consider it? It will be more expensive than what you’ve been paying, but your daughter won’t need to worry about transitioning doctors or her deductible for such a short time.
3. Third, check our annual enrollment materials sent to your home [add in when materials are sent]. You’ll be able to add her back to your health plan effective [insert effective date]. To avoid pre-existing condition limits, be sure that she maintains coverage. When you enroll your daughter in the fall, you’ll be asked for documentation that she’s had continuous coverage.

Q. My son age 24 was dropped last year. He has a pre-existing condition. When I enroll him, will there be limits on his coverage?

[Modify based on your plan specifics.] A. Maybe. If your son had continuous coverage after he was dropped from our plan and until he rejoins our plan, then no. However, if your son has been uninsured since he became ineligible for our plan, then yes, he would be subject to limits. [If your plan has pre-existing exclusions, you can point employees to the newly created high-risk insurance pools that exist until 2014, when all pre-existing conditions are banned.]

Q. What will it cost to cover my adult child?

A. Check the enrollment materials mailed to your home [insert when materials are mailed]. At that time, we’ll share the 2011 premium costs.

Q. What documentation will I need to provide cover my child?

A. In 2011, you will need to provide [insert documentation requirements relating to adult child’s employment]. Annually, we will no longer require you to complete the student certification process, because full-time student status will no longer be an eligibility requirement.

We’re focused on PPACA

We’re continuing to watch for final regulations and committed to helping you interpret them. We’ll be updating this blog with suggestions, tips and more sample language. If you have specific questions or would like help creating a long-term strategy, please give us a call at 888-550-5251 or send us an e-mail at info@benzcommunications.com!

And be sure you didn’t miss our previous blog posts about health care reform:

• March 21, 2010: What to tell your employees about health care reform
• April 26, 2010: Absorbing the new law
• April 26, 2010: PPACA employee announcement
• May 24, 2010: Age 26 dependents—what’s the right message?

Common sense caveat: These sample questions are from Benz Communications, an employee benefits communication consulting firm. We know benefits. We know what your employees care about. We know how to help you bridge the two. We are not attorneys and nothing in this constitutes legal advice or anything coming close to it. In addition, as we all know, the legislation and regulations are in flux. This information is accurate at the time it was published but you should consult the HHS website or other sources for the most up-to-date information at the time you communicate to employees.