Report to Congress: Annual Report on Self-Insured Group Health Plans (Mar. 2016); Appendix A, Group Health Plans Report: Abstract of 2013 Form 5500 Annual Reports Reflecting Statistical Year Filings (Jan. 2016, v. 1.0); Appendix B, Self-Insured Health Benefit Plans 2016: Based on Filings Through Statistical Year 2013 (Sept. 24, 2015)
The DOL’s sixth annual report to Congress on self-insured health plans suggests a trend (based on 2004–2013 data) away from self-insurance among relatively small plans and toward self-insurance among relatively large plans. The report is required by health care reform and provides general information about the characteristics of private-sector self-insured health plans (including number of participants, benefits offered, funding arrangements, and plan assets), as well as publicly available financial information about their sponsoring employers. It updates the DOL’s 2015 report (see our Checkpoint article) and is based on 2013 Form 5500 filings.
The DOL acknowledges that the report underestimates the total number of self-insured health plans due to inherent challenges in data collection, including the lag time in obtaining Form 5500 data and the fact that the Form 5500 data includes only plans with 100 or more participants or assets held in trust. The DOL also indicates that refinements in the way that plans were counted for this year’s report resulted in lower numbers that make it harder to identify trends over time. Nevertheless, the report concludes that although the fraction of group health plans that are self-insured (or partly self-insured) declined from 55% in 2004 to 49% in 2013, the percentage of plan participants covered by self-insured (or partly self-insured) plans increased from 78% to 83%. The report’s appendices provide details and indicate, among other things, that the percentages changed only slightly between 2012 and 2013.
EBIA Comment: As recognized in the report, changes in counting methods and reliance on Form 5500 filings limit its usefulness in identifying self-insurance trends, especially among small plans that are not required to file Form 5500 because they are unfunded, insured, or a combination of unfunded and insured. And because the report is based on 2013 data, it does not reflect the implementation of several health care reform requirements that took effect in 2014 (such as the annual fee on health insurers and—for insured plans in the small group market—rating limitations and the requirement to offer the essential health benefits package). For more information, see EBIA’s Self-Insured Health Plans manual at Sections IV.B (“Financial Considerations”), IV.E (“Prevalence and Characteristics of Self-Insured Health Plans”), and V.D.1.c (“Table of Health Care Reform Provisions Applicable to Self-Insured Health Plans”). See also EBIA’s Health Care Reform manual at Section XXXVI.E (“Annual Report on Self-Insured Plans (Using Information From Form 5500s)”). You may also be interested in our recorded webinar “Self-Insuring Your Health Plan: Why Now, and What Needs to Be Done?”
Contributing Editors: EBIA Staff.