Q1: As “church plans,” are our medical benefit plans exempt from this new legislation?
A1: No. The new legislation will have some effect on all denominations in some manner. In the polity of the United Church of Christ, each ministry is an individual employer that must be in compliance.
Q2: Is the UCC Medical Plan the only UCC benefit plan affected by the new rules?
A2: No. There are parts of the new legislation that also affect the Flexible Benefit Plan for UCC Ministries (also known as the Flexible Spending Account, or FSA, Plan).
Q3: Will the new rules change the basic design of our Medical Plan today?
A3: Yes, but to a limited degree. The health care reform legislation “grandfathers” certain existing group health plans. Grandfathered plans are subject to some, but not all, of the requirements of the health care legislation. A group health plan is grandfathered under the legislation if the plan was providing coverage to any individual on March 23, 2010, the date of enactment of the legislation. Since the UCC Medical Plan meets that criterion, it is a grandfathered group health plan under the legislation.
Q4: What does it mean to be a grandfathered group health plan under the health care reform legislation?
A4: A grandfathered plan has the advantage of being able to continue to provide access to the doctors, medical service providers, and pharmacy benefits as we have them today. As a grandfathered plan, the UCC Medical Plan is required to comply with certain coverage and benefit requirements, but these will have less of an impact on premiums than some of the administrative and reporting requirements applicable to other group health plans.
Q5: How does the new health reform legislation help persons who have pre-existing conditions and are without medical benefits coverage?
A5: Effective July 1, 2010, the new legislation establishes a high risk pool program for eligible persons with pre-existing conditions. The federal government has already reached out to each state to begin coordinating the availability of benefits between existing state programs and the new federal mandate. Persons who are now precluded from applying to the UCC Medical Plan may find that coverage will be available under this new state/federal partnership. As we have additional details on the programs available from individual states, we will make that information available.
Q6: I am participating in the Flexible Benefit Plan for UCC Ministries (FSA Plan) as part of my health benefits. Will there be changes to that Plan?
A6: Yes. The new legislation reduces the tax benefits of the FSA in two important ways:
A. Limitation on FSA benefits
Effective January 1, 2013, amounts to be reimbursed tax-free are limited to $2,500.
B. Over-the-counter items are no longer eligible for reimbursement.
Effective January 1, 2011, the FSA Plan will no longer be permitted to reimburse participants for expenses incurred for over-the-counter items purchased without a prescription.