Prior to enrolling in the COSE MEWA, all employers must read and agree to the administration and compliance guidelines. Employers are also required to provide a Summary of Benefits and Coverage (SBC). Please see the below links for detailed information on employer requirements, plan SBCs, Underwriting Guidelines and more.
Administration and Compliance Guide
This guide contains information on administering your plan and provides summary guidance with applicable state and federal laws.
Medical Summary of Benefits and Coverage
Health insurers are required by the Affordable Care Act to provide a Medical Summary of Benefits and Coverage (SBC). An SBC helps you better understand your health plan by using a standard format that helps you easily compare plans.
These guidelines summarize your group’s requirements for participating in the MEWA. Refer to this document for help with setting up funding rate contributions, determining residency and enrollment requirements, and more.
Summary of Plan Description
The summary plan description (SPD) describes benefits and terms of coverage. Medical Mutual will create a generic SPD by wrapping the Plan Document with the Benefit Book for each employee. However, employers are responsible for creating and distributing group-specific plan documents and the SPD. To help you create a group-specific SPD, the COSE MEWA offers a template.
Summary Plan Description Help
Premium Only Plan
A Section 125 Premium-Only-Plan (POP) is a cafeteria plan that lets employees pay their health insurance premiums using tax-free dollars. Traditionally, POP plans have been used in combination with employer-sponsored group health insurance.
Medicare Exception Process and Forms
Because this is a MEWA, if at least one Participating Employer has at least 20 full and/or part time employees, Medicare is deemed to be secondary even for Participating Employers having fewer than 20 employees. However, there is an exception process for certain individuals entitled to Medicare on the basis of age for a Participating Employer with fewer than 20 employees.
In order to apply for this exception (and avoid the associated costs for the employee and your business), if you have a Participant and/or Participants spouse that become eligible for Medicare, you must provide a notice in writing for whom the Participating Employer is requesting Medicare be the primary payer. Written notice must be provided to those employees prior to them turning 65. Each Participating Employer must also send to Medical Mutual any required census data or application form requested by Medical Mutual. For more information, please contact your broker or sales representative.
Medicare Part D
A prescription drug plan is considered “creditable” if its benefits are at least as good as government-defined Medicare Part D prescription drug plans. To help Medicare-eligible participants decide whether or not to sign up for Part D coverage, group health plan sponsors are required by the federal government to send Medicare Part D (prescription drug) “creditable coverage” notices to their Medicare-eligible employees and dependents at various times during each year.
As a courtesy, Medical Mutual will send your Medicare-eligible plan participants (employees and dependents) their annual notice by the CMS deadline in October of each year. Medicare eligibility of your plan participants is based on information in Medical Mutual’s system – participants who either will be age 65 or older at any time during the year, or who are under age 65 but otherwise qualify for Medicare due to disability. If you know of other individuals covered by your plan who are eligible for Medicare but you have not communicated this information to Medical Mutual, it is your responsibility to notify those participants.
The COSE MEWA offers a variety of plans to participating employers and their employees. Most of these plans are creditable, regardless if the participant is Medicare Primary or Medicare Secondary, except for the two plans mentioned below:
For the HSA 4000 w/PD Rx and the HSA 6550 w/MMRx:
If Medicare pays primary to group coverage, then these plans are NOT creditable.
If Medicare pays secondary to group coverage, then these plans are creditable.
If you have any questions about the creditable coverage notice or your responsibility to provide it to your Medicare-eligible participants and dependents, please contact your Medical Mutual representative or broker.