What is the Federal premium reporting requirement?
The Consolidated Appropriations Act (2021) was passed by Congress on December 21, 2020 and signed into law on December 27, 2020. It is responsible for the implementation of a new annual reporting requirement that requires all health insurance issuers, employer-based health plans, and other group health plans to report an average monthly premium paid by employees and an average monthly premium paid by employers every plan year.
Who must report?
The department of Civil Service is essentially responsible for gathering and reporting this information. However, Participating Agencies and Participating Employers will play a role in how that information is gathered and reported.
When is reporting due?
These premium amounts must be reported for the 2020 and 2021 plan years by December 27, 2022 by the Department of Civil Service. To meet this federal requirement, Civil Service needs to collect this information from Participating Agencies and Participating Employers. This will also be an annual requirement going forward. For plan year 2022 and beyond, this information will be required to be submitted by Civil Service by June 1 following each plan year.
What are the school districts’ role?
Since Civil Service has a deadline, so will school districts. For plan years 2020 and 2021, a mandatory survey was issued for completion by October 14, 2022. Agencies are required to utilize a new page in NYBEAS to input their total annual employee contributions by plan year. Districts will need to enter the total annual enrollee share of the NYSHIP health insurance premium for each benefit plan (e.g., Empire Plan, Excelsior Plan, or HMO) and for each coverage option (e.g., individual coverage, family coverage). The total annual EE share includes amounts you deducted from payroll checks or pensions, or billed directly. It is important to remember that the total annual employee share of the premium represents the total amount of all employees, retirees, vestees, dependent survivors, COBRA, and Young Adult Option paid for coverage for the plan year. If your agency paid 100 percent of the premium for your enrollees, you would still need to complete the page by inputting $0.00.
This must be completed each plan year going forward. Civil Service anticipates 2022 data collection from school districts to begin in early 2023. School districts should be on the lookout for notification as to when this needs to be completed.
Thomas is a member of Cerini & Associates’ audit staff where he works with our education and school district clients. He conducts claims audits at various school districts on Long Island.