As of June 2018, there is not yet an association group plan nor customized health plans that the AIA Trust can offer to AIA members—but the AIA Trust is continuing to monitor the situation in the event that changes. The continuing Affordable Care Act (ACA) still defines only two ways in which someone can purchase private insurance: through their employer or as an individual. Currently groups (such as membership associations) cannot band together and purchase health insurance on behalf of their members, and until that changes, there are no immediate plans with association group pricing that the AIA Trust (or anyone) can offer. However, there may be changes on the horizon.
An Executive Order was made in October 2017—which has no force of law—to direct the Department of Labor (DOL) to consider potential Association Health Plan (AHP) opportunities.
The Final Rule was released on June 19, 2018 with an applicability date of September 1, 2018 for new fully insured AHPs. The DOL used its delegated authority under the Employee Retirement and Income Security Act of 1974 (ERISA) in developing this regulation. Therefore, the focus is on employer groups including working owners (sole proprietors), and insurance carriers may respond by offering new or revised products based on their insurance filings with the respective states. Availability of new association-type programs will depend on whether insurance companies determine them to be viable and if so, whether new state insurance filings are required.
Unfortunately, a recently conducted insurer survey indicated that less than 6% of insurers are interested in pursuing AHPs—in part due to uncertainty as to how the new plans will impact their current ACA offerings and also concerns about possible adverse selection within AHPs.
Here is a recent press release from the Department of Labor: https://www.dol.gov/newsroom/releases/osec/osec20180619
Proposed regulations related to Health Reimbursement Arrangements (HRAs) may expand employers’ ability to offer HRAs to their employees which could be helpful to many. Once these new HRA regulations are finalized, the AIA Trust will communicate them. However, there are complex tax issues involved so this may not be determined until later in 2018.
The AIA Trust, which is governed by AIA members for the benefit of AIA members, continues to monitor these developments weekly. Updates about healthcare coverage are posted to our resources page, found by clicking here.
If and when the AIA Trust can identify any available plans that would be beneficial to AIA members, it will move forward expeditiously. The AIA Trust will publish updates on its website and in the AIA Trust quarterly member newsletter. Members who don’t currently receive the newsletter may sign up for free on the AIA Trust website by clicking here.