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Volume 3, Issue 40 · October 13, 2010

Blue Care Network updating certificates and riders to comply
with PPACA

BCN is updating certificates and riders on Jan. 1, 2011, to comply with the near-term changes required by the Patient Protection and Affordable Care Act, including:

The information in this alert applies to:

  • BCN groups with a plan year that begins Jan. 1, 2011
  • BCN groups with a plan year that begins on a date other than Jan. 1, 2011 (BCN groups with a plan year rider will have their coverage automatically updated to reflect PPACA provisions at their renewal.)
  • BCN groups that have confirmed with BCN that they’ll retain grandfathered status

NOTE: BCBSM will provide its certificate and rider update in a future alert.

PPACA certificate addendums

BCN group certificates will be updated effective Jan. 1, 2011, to apply all currently required health care reform provisions including extension of dependent coverage through age 26 and 100 percent coverage for preventive services.

Groups with a plan year that begins on Jan. 1, 2011, will automatically be updated with the new provisions. Group-wide changes aren’t necessary.

Here are the certificates that have been updated:

  • BCN1
  • BCN5
  • BCN10
  • BCN BASIC
  • Self-Referral Option (100 percent preventive coverage applies to both tier 1 and tier 2 services)
  • BCN65
Rating and benefit change process for BCN groups with a plan year that begins on a date other than Jan. 1, 2011

Most BCN groups have a Jan. 1, 2011, plan year. However, for groups with a plan year beginning before Jan. 1, 2011, BCN must make interim changes by adding riders to comply with PPACA provisions. On Jan. 1, 2011, the interim riders will be removed as the certificates will be updated to comply with PPACA provisions.

Groups with a plan year that begins after Jan. 1, 2011

For these groups, BCN must make interim changes by adding riders to remove the PPACA provisions effective Jan. 1, 2011, based on the certificate updates until the groups’ plan year begins. Once the group’s plan year begins, the minus (HCRMS) and cost-sharing for preventive services (PSCR) riders are removed in order to comply with PPACA.

Here is a chart with more detail:

Start of group’s plan year
Description of change*
Does underwriting need to issue a renewal? (includes new business)
Group Wide Change?
Rate Change?
Sept. 23 – Dec. 31, 2010
Step 1: On plan year start date, add HRPLUS and PSWHMO riders
Yes
(with PPACA riders)
Yes
Yes
(at renewal or new business)
Step 2: On Jan. 1, 2011, remove HRPLUS and PSWHMO riders
No
Yes
No
Jan. 1, 2011
All certificate language changed to comply with PPACA
Yes
No
Yes
(at renewal or new business)
Jan. 2 – Sept. 22, 2011
Step 1: On Jan. 1, 2011, add HCRMNS and PSCR riders
No
Yes
No
Step 2: On plan year start date, remove HCRMNS and PSCR riders
Yes
Yes
Yes
(at renewal)
* A list of riders is provided below in this alert

Rating and Benefit Change Process for BCN groups with grandfathered status

NOTE: BCN is treating all groups as “new” health plans. This chart only applies to groups that confirmed with BCN that they will be treated as a grandfathered plan. You can read this Blue Alert for more about BCN’s position on grandfathering.

Start of group’s plan year
Description of change*
Does underwriting need to issue a renewal? (includes new business)
Group Wide Change?
Rate Change?
Sept. 23 – Dec. 31, 2010
Step 1: On plan year start date, add HRPLUS and HCRGF riders on plan year start date
Yes
(with PPACA riders)
Yes
No
Step 2: On Jan. 1, 2011, remove HRPLUS rider and Add PSCR
No
Yes
No
Jan. 1, 2011
Jan. 1, 2011
effective date
Add PSCR and HCRGF riders
Yes
(with PPACA riders)
Yes
Yes
(at renewal)
Jan. 2 – Sept. 22, 2011
Step 1: On Jan. 1, 2011, add HCRMNS, PSCR and HCRGF riders
No
Yes
No
Step 2: On plan year start date, remove HCRMNS rider
Yes
(with grandfather rider)
Yes
Yes
(at renewal)

NOTE: We’ll process group-wide changes automatically to apply the appropriate riders.

PPACA riders

These riders apply to BCN groups with a plan year that begins on a date other than Jan. 1, 2011, and BCN groups that have confirmed their grandfather status. The charts above indicate how these riders will be changed to comply with PPACA:

  • HCRGF – informs members that their health plan is a grandfathered plan as mandated by PPACA and applies to all grandfathered groups
  • HCRMNS – removes dependent coverage through age 26, applies pre health care reform guidelines, available to groups with plan years that begin after Jan. 1, 2011
  • HRMN65 – BCN65 rider removes dependent coverage through age 26 and applies pre health care reform guidelines. The rider is available to groups with plan years that begin after Jan. 1, 2011.
  • HRPLUS – extends dependent coverage through age 26, updates the certificate language specific to rescissions, access to OB/GYNs and pediatricians and is available to groups with plan years that begin prior to Jan. 1, 2011
  • PSCR – applies cost sharing to preventive services and is available to groups with plan years that begin after Jan. 1, 2011 and to grandfathered groups
  • PSCR65 – BCN65 rider applies cost sharing to preventive services. The rider is available to groups with plan years that begin after Jan. 1, 2011, and grandfathered groups
  • PSWHMO – applies 100 percent coverage to preventive services and is available to groups with plan years that begin prior to Jan. 1, 2011

Questions? Contact your managing or general agent.

The information in this document is based on BCBSM's review of the national health care reform legislation and is not intended to impart legal advice. Interpretations of the reform legislation vary, and efforts will be made to present and update accurate information. This overview is intended as an educational tool only and does not replace a more rigorous review of the law's applicability to individual circumstances and attendant legal counsel and should not be relied upon as legal or compliance advice. Analysis is ongoing and additional guidance is also anticipated from the Department of Health and Human Services. Additionally, some reform regulations may differ for particular members enrolled in certain programs such as the Federal Employee Program, and those members are encouraged to consult with their benefit administrators for specific details.

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