While there is not currently an association group plan nor customized health plan that the AIA Trust can offer to AIA members, there is some cause for optimism.
At present, 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. The AIA Trust is continuing to monitor the situation in the event this changes.
However, the Department of Labor (DOL) announced new regulations on June 19, 2018, which expand the definition of Association Health Plans (AHPs). This expansion applies to firms and the self-employed (working owners). The Trustees are committed to finding a healthcare solution as soon as possible and are now working in conjunction with our independent consultants, the AIA Small Firm Exchange, and an insurance agency to explore the potential new options that are permissible for association plans under the new DOL guidance.
Some members have recently observed that other associations are offering healthcare plans to their members. Upon further investigation, it appears that these are either plans that are available to all on healthcare exchanges and not endorsed plans (similar to what the AIA Trust was offering in the past but was terminated due to unacceptable messaging) or are offered by a statewide (not national) organization which meets the DOL commonality of interest guidelines. For example, an industry group of several different trades could meet the AHP guidelines in either a single state or in a common metropolitan area that crosses several states (such as the New York metropolitan area). On a nationwide basis, there must be a common profession or trade, such as architects.
It’s important to note that a fully insured AHP option is dependent on the insurance companies’ interest in offering such products in the marketplace and their obtaining approvals from the various state regulatory agencies. The DOL guidance clearly reaffirms the regulatory oversight authority of each state and approval timelines vary greatly. It is yet unknown how many insurance companies will offer these products. To date, United HealthCare has expressed an interest and our team is holding ongoing discussions with their representatives.
As we have updates on this topic, we will share them on our AIA Trust website page here: https://www.theaiatrust.com/healthcare-coverage/. We also regularly update our page of healthcare resources found here: https://www.theaiatrust.com/healthcare-coverage/national-healthcare-reform/.
In addition, AIA members not already receiving the quarterly AIA Trust newsletter, Managing Your Risks, may sign up for it here: https://www.theaiatrust.com/news/, which will continue to publish healthcare coverage updates.