Time to revisit the SHOP - Highlights from the HHS Notice of Benefit and Payment Parameters for 2016
(Posted on 05/11/15)
Since 1/1/2014, there has been little incentive for an employer to enroll on the SHOP; same products (but fewer choices), same prices (but less flexibility), and the inconvenience of an additional hurdle to clear in terms of installing and servicing our clients. The only hook it had was the small business tax credit, for which very few businesses actually qualified (See Below for eligibility criteria). The convergence of these factors led to the very low enrollment through the SHOP in its first two years.

The final rules issued on the 2016 Benefit and Payment Parameters may change that. The final rules contain updated market regulations that pertain to the individual and small group markets both on and off exchange in 2016.
2016 will bring big changes to the SHOP market and introduce some features that were intended to be available to consumers from the beginning, but were delayed due to logistics and technical challenges.

Here are some of the highlights to look forward to in 2016 (See Below for the CMS fact sheet):

- Small Group Market Expansion - The definition of a small group will be revised to encompass groups of up to 100 employees (not withstanding pending legislation to delay this change). Look out for the option to grandmother existing 51-99 business on a carrier-by-carrier basis.

-Big Changes to SHOP:
The employee choice model is scheduled to be in all states in 2016, which means an employer can offer plans from multiple carriers on the SHOP platform.

Minimum Participation Rate is set at 75% for the NJ SHOP market. That is not news, but what will count as a valid waiver is. SHOP participation will be based on full-time employee participation in SHOP and "employees enrolled in coverage through another group health plan, in governmental coverage (such as Medicare, Medicaid, or TRICARE), in coverage sold through the individual market, or in other minimum essential coverage."

The rules also permits SHOPs to assist employers with COBRA administration.

- FFM Training for Agents and Brokers will be done through approved vendors as opposed to the CMS Learning Network. It will come with CE Credits and will be subject to a fee.

- Additional Individual SEPs for coverage expiring from a non-calendar year plan in the group market. (To address the plaguing question of "what happens if my employer reduces contribution at renewal, but I am outside of open enrollment??")

- 2016 Individual Open Enrollment will be from 11/1/2015 - 1/31/2016.