Module 10 - Managing Flexible Benefit Plans Flashcards
(39 cards)
Outline factors that have influenced the development of group flexible benefit plans in Canada.
Flexible benefit plans respond to several trends that are driving rising benefits costs and changing workplace demographics:
(a) Escalating benefits costs due to government cost shifting through reductions in coverage under provincial/territorial health plans
(b) An expanding range of innovative and high-cost health care services
(c) Health care cost increases in excess of general inflation levels
(d) An aging population
(e) An increasingly diverse workforce (e.g., gender, race, ethnicity, age, sexuality, language, education, culture and religion) with increasingly diverse heath care needs.
In addition to these factors, many employees have become more educated and involved consumers thanks to greater access to information and the growing focus on prevention and wellness. As a result, many employees increasingly value choice in their group benefit plans.
Identify reasons plan sponsors implement flexible benefit plans.
Plan sponsors typically cite these reasons for implementing flexible benefit plans:
(a) Meeting diverse plan member needs
(b) Improving attraction and retention of employees
(c) Increasing plan member understanding of the cost of benefits
(d) Containing or reducing benefits costs
(e) Meeting competitive pressures
(f) Delivering benefits in a more tax-effective manner
(g) Harmonizing benefit arrangements following mergers and acquisitions.
Explain how a traditional plan with no choice differs from a traditional plan with add-ons.
In a traditional plan with no choice, the plan sponsor provides a fixed offering of benefits, and plan members have no choice in benefit types or levels of coverage, aside from electing single or family coverage (or opting out if they have spousal coverage). In a traditional plan with add-ons, plan members are allowed to add on to the traditional benefit plan by supplementing coverage in certain benefit areas (typically by adding optional life, optional accidental death and dismemberment (AD&D), or optional critical illness (CI) insurance). A traditional plan with add-ons is not considered to be a flex plan because it offers only a small degree of choice, for which the plan member typically pays.
Explain how a modular approach to flexible benefits differs from the full flex approach.
The modular approach provides plan members with a choice of at least two predefined benefits modules or packages (e.g., a package for basic, medium or high coverage). Plan members who select a module that offers a high level of coverage must usually contribute to the cost of benefits through payroll deduction.
Under the full flex approach, plans offer a wide range of different options to plan members. There is typically a core plan, which includes a minimum level of coverage for life and long-term disability (LTD) that is mandatory for all plan members. Plan sponsors usually choose to offer some form of catastrophic health coverage in the core plan, which could include drug coverage after satisfaction of a high deductible and emergency out-of-country coverage. Usually, plan members receive flex credits (or flex dollars) from the plan sponsor. Plan members use the flex credits to purchase benefits from a menu of options with predetermined price tags. If the flex credits are more than the price of the selected benefits, plan members may choose among several options to use the remaining amount, depending on what the plan sponsor offers (e.g., health care spending account (HCSA), taxable spending account, group registered retirement savings plan (RRSP), tax-free savings account (TFSA) or taxable cash). If the flex credits are not sufficient to cover the price of the selected benefits, plan members pay the difference through payroll deduction.
Describe the total rewards approach to flexible benefits.
Total rewards flex plans take a total compensation approach that provides plan members with the most extensive choice. Depending on the parameters of the flexible benefit plan, plan members could have choice in benefits, pay, pension/retirement contributions and vacation; however, it is important to carefully consider the tax implications.
For example, some plans allow plan members to purchase vacation with flex credits, so they receive more vacation in place of benefits. Plan members must use additional vacation days they purchase with flex credits in the year of purchase; otherwise, there may be tax implications. These plans may also allow plan members to sell vacation and receive less time off in exchange for more flex credits to purchase additional coverage. Most employers limit the number of vacation days that plan members can sell to between one and five days. Plan members must retain the minimum number of vacation days mandated by employment standards legislation in their province or territory of employment. Flex credits obtained from selling vacation days are taxable to plan members.
Describe price tags and flex credits and explain how they are used in flexible benefit plans.
Flexible benefit plans typically use price tags and flex credits, which are communicated to plan members in the benefits selection process. Price tags are the prices or rates (cost of purchasing) for each benefits coverage option the plan sponsor offers.
Flex credits represent the plan sponsor’s contribution to the plan costs. The plan sponsor allocates flex credits to plan members, and plan members use them to purchase benefits coverage. The number of flex credits plan members receive relates to the setting of price tags, as these components work together to influence plan member choice. Factors that play a role in determining the number of flex credits plan sponsors make available to plan members are funding sources and the pricing objectives of the flex plan.
Depending on the price tags of the options plan members select and the flex credits they receive, plan members may have to contribute additional dollars through payroll deduction to purchase the coverage they want.
Outline pricing objectives used by plan sponsors to guide decisions on flex credits and price tags and provide examples that align with each of the objectives: List
Realistic pricing
Equity pricing
No-losers pricing
No additional plan sponsor cost pricing
Outline pricing objectives used by plan sponsors to guide decisions on flex credits and price tags and provide examples that align with each of the objectives: Realistic Pricing
This approach sets price tags that reflect the cost of the coverage. The plan sponsor can then allocate flex credits to plan members based on realistic prices. With realistic pricing, plan members can develop a better understanding of the value of the program since the price tags for each option reflect the expected claims cost.
Outline pricing objectives used by plan sponsors to guide decisions on flex credits and price tags and provide examples that align with each of the objectives: Equity Pricing
Each plan member receives an equal dollar amount or percentage of pay in flex dollars, regardless of their dependent coverage status (i.e., members with and without dependents receive the same allocation). The plan sponsor provides equal flex credits to all plan members based on the average cost of coverage for single plan members only, average cost of coverage for plan members with dependents (more costly than single), average cost of coverage for all plan members or as a percentage of pay.
Outline pricing objectives used by plan sponsors to guide decisions on flex credits and price tags and provide examples that align with each of the objectives: No-losers pricing
This approach structures flex credits and price tags to allow plan members to obtain the same (or most comparable) level of coverage that they would have had under a previous, traditional plan without any cost increase. To meet this objective, plan sponsors use component credit allocation, allocating flex credits to plan members for each type of benefit previously offered. Typically, plan sponsors base credits for benefits not related to pay, such as extended health care, on flat-dollar components, while they base credits for pay-related benefits, such as LTD, on percentage-of-pay components.
Outline pricing objectives used by plan sponsors to guide decisions on flex credits and price tags and provide examples that align with each of the objectives: No additional plan sponsor cost pricing
The plan sponsor contributes the same level of overall dollars toward the flexible benefit plan as it would have contributed to the previous benefit plan. For example, if the average plan sponsor cost for the traditional plan was $2,500 per plan member and the estimated cost for the new flexible benefit plan is $3,000 per plan member, the flex credit allocated would be $2,500 per plan member, with the plan members funding the additional $500.
Explain how the total plan sponsor cost of a flexible benefit plan is determined.
The total plan sponsor cost of a flexible benefit plan can be estimated by projecting the expected claims cost (claims adjusted for inflation plus expenses and taxes), adding the total flex credits (plan sponsor contribution) and subtracting the total price tags (plan member contribution):
Total plan sponsor cost = expected claims + expected expenses and taxes + flex credits – price tags.
Identify steps generally involved in setting price tags under a flexible benefit plan.
Data collection and analysis
Preliminary option pricing
Preliminary subgroup pricing
Consideration of adverse selection and other changes that will impact benefit costs
Calculation of taxes and administration fees.
Adjustment to realistic price tags
Determination of no-coverage or opt-out pricing (if applicable)
Pricing by business unit or location
Describe the disadvantages of using subsidized pricing in a flexible benefit plan.
While subsidized pricing may encourage plan members to select a particular option, it also adds a layer of complexity to the pricing process and can have some disadvantages. Subsidized pricing may cause the plan sponsor to move away from the objective of realistic pricing. It also makes it more difficult for plan members to understand the program cost, since subsidized price tags may significantly understate the actual cost of providing benefits.
Explain what influences a plan sponsor’s decision to include limitations on a plan member’s ability to opt out of coverage in a flexible benefit plan.
Plan members may be allowed to waive or decline coverage for certain benefits. The plan sponsor decides whether plan members will be allowed to opt out and for which benefits. It is rare for plan sponsors to allow plan members to opt out of all benefits due to the potential for adverse selection, which can drive up the cost for the remaining plan members. In addition, many plan sponsors have a benefits philosophy to provide plan members with a certain minimum level of benefits coverage.
Some plan sponsors may allow plan members to opt out of extended health care and dental benefits entirely; however, plan sponsors generally require plan members to have coverage under another plan, such as a spouse’s group benefits plan, before permitting plan members to waive coverage. Other benefits (e.g., life and LTD) usually have a minimum core level that plan members cannot waive.
If benefits are insured, this impacts the decision about whether or not to allow plan members to decline coverage. As discussed previously, the insurer may be unwilling to underwrite certain benefits if participation is too low.
Differentiate between premium or deposit billed rates and price tags as they relate to flexible benefit plans.
In insured plans, the insurer sets premium rates. These premium rates may or may not match the price tags communicated to plan members in the benefits selection process. For example, if the plan sponsor is subsidizing the price tags for the core level of insured extended health care benefits, the premium rate billed by the insurer for the health benefit could be $50 per month/member, but the price tag charged to a plan member could be $40 per month.
This may also happen if the plan is self-insured with an administrative services only (ASO) arrangement. If the plan sponsor is using a billed-in-advance payment option, the monthly deposit levels or deposit rates set by the insurer or TPA may or may not match the price tags the plan sponsor communicates to plan members in the benefits selection process.
Identify possible sources of funding for flex credits.
Plan sponsor contributions to current plan
Reallocation of funds from restructuring benefits provided within the flexible benefit plan
Restructuring benefits provided outside the flexible benefit plan
Additional plan sponsor contributions allocated to all plan members
Additional plan sponsor contributions through wellness credits
Payroll deductions
Identify methods a plan sponsor can use to test the overall feasibility of the flexible benefits pricing structure.
Plan sponsor cost analysis: This compares the total plan sponsor cost before the flexible benefit plan to the expected cost of the flexible benefit plan.
Winner and loser analysis: This compares a plan member’s situation before and after implementation of the flexible benefit plan. It reviews plan member contributions for each plan to determine the impact of the introduction of the flexible benefit plan. There will always be winners and losers under a new flexible benefit plan (i.e., there is no perfect scenario where every plan member “wins”).
Describe adverse selection and outline strategies, other than price tag adjustments, that can be applied to a flexible benefit plan to minimize the risk of adverse selection yet still offer some plan member choice
Adverse selection occurs when plan members are aware that they will use a particular benefit and select the benefit option that provides the highest level of coverage at the lowest cost (based on their best estimate of the out-of-pocket expenses they would otherwise incur). For example, plan members who know they need expensive bridgework will tend to select a dental care option that is priced lower than the cost they otherwise would have had to pay to obtain the bridgework.
Strategies that can be applied to a flexible benefit plan to minimize adverse selection yet still provide some plan member choice include:
Implementing step-up or step-down limitations (i.e., staircase rule)
Implementing lock-in provisions
Implementing packaged options
Structuring benefit options strategically
Using HCSAs for predictable expenses
Using opting-out disincentives
Staircase rule
The staircase rule applies a maximum increase or decrease in coverage from one plan year to the next. This prevents plan members from moving from the lowest level of coverage to the highest after learning they might require medical or dental treatment for a particular condition, and vice versa when the need no longer exists. There may be exceptions to allow for changes in options related to certain life events.
Lock-in provisions
When plan members choose certain options (such as the highest level of benefits coverage), they cannot change their selections for a specified period of time, referred to as the “lock-in” period (usually two or three years). This protects the plan from plan members staying in an option only for the period they expect to receive treatment or care and then dropping down to a less expensive option as soon as they have incurred these expenses. Lock-in provisions also ensure that premiums for high-level options are paid for at least a minimum period.
Packaged options
Packaged options reflect pre-set combinations of benefits coverage that combine coverage for what might be predictable and budgetable expenses (e.g., dental care) with benefits coverage for catastrophic and nonpredictable expenses (e.g., emergency out of Canada health care).
Opt-out disincentives
Plan members who waive or opt out of coverage for a certain benefit are provided with less than the full value of that benefit in terms of flex credits.
Explain how benefits provided under a flexible benefit plan are taxed.
In general, benefits under a flex plan are taxed in the same way as those under a traditional plan as long as the plan meets the set criteria (i.e., plan members must choose their benefits and how to fund them before the beginning of the plan year and, subject to certain exceptions, these selections must be irrevocable). Exceptions to irrevocable selection are life events (e.g., birth or death of a dependent, change in marital status or loss of insurance coverage under a spouse’s plan) or changes in employment status (e.g., full-time to part-time employment). Changes are only effective from the date of the life event or employment status change and do not apply retroactively.
The mere allocation of flex credits by a plan sponsor does not create a taxable benefit in the hands of the plan member if certain conditions are met and flex credits are notional. Flex credits are considered to be notional amounts if they have no redemptive value, and the plan member forfeits nothing of value to acquire them.
Canada Revenue Agency (CRA) views flex credits as plan sponsor benefit premiums, not plan member earnings. Flex credits are generally not taxable until the plan member uses them to purchase benefit selections. The tax treatment of flex credits depends on the type of benefits the plan member purchases. For example, when a plan member chooses, before the beginning of the plan year, to have a portion of their flex credits deposited into a TFSA or an RRSP, the amount received or deposited is included in the plan member’s income as salary or wages when it is received or deposited.
Except in Quebec, plan sponsor premium contributions to a PHSP, such as a group benefits plan, are not considered income to the plan member. Note that this tax treatment is not extended to life, AD&D or CI benefits; flex credits used to purchase these types of coverage are considered taxable to plan members. In Quebec, flex credits used to purchase health and dental coverage are subject to provincial income tax.