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DOL Reports to Congress on Prevalence and Characteristics of Self-Insured Health Plans

Report to Congress: Annual Report on Self-Insured Group Health Plans (Mar. 2015); Appendix A, Group Health Plans Report: Abstract of 2012 Form 5500 Annual Reports Reflecting Statistical Year Filings (Mar. 2015); Appendix B, Self-Insured Health Benefit Plans 2015: Based on Filings Through Statistical Year 2012 (Sept. 16, 2014)

Report

Appendix A

Appendix B

The DOL has submitted its fifth annual report to Congress on self-insured health plans. The report, required by health care reform, provides general information about the characteristics of self-insured health plans (including plan type, number of participants, benefits offered, funding arrangements, and benefit arrangements) and publicly available financial information for their sponsoring employers. It updates the DOL’s 2014 report (see our article) and is based on 2012 Form 5500 filings (the latest year available). In addition to the lag time in obtaining Form 5500 data, the report acknowledges other inherent challenges in data collection. For example, Form 5500 filings generally exist only for private-sector plans that cover 100 or more participants or hold assets in trust; thus, the report necessarily underestimates the total number of self-insured (and partly self-insured) health plans.

The report indicates that although the fraction of group health plans that are self-insured (or partly self-insured) has declined slightly over time, the portion of plan participants covered by self-insured or partly self-insured plans has increased. The report’s two appendices provide details: From 2011 to 2012, the percentage of Form 5500-filing plans that were self-insured or partly self-insured remained at 49%, while the percentage of participants covered by these plans increased slightly, from 83% to 84%. (For comparison, in 2003 the percentage of self-insured or partially self-insured plans was 56%, and the percentage of participants covered by these plans was 78%. But the report also notes that data may not be directly comparable due to changes in methodology.) Appendix B suggests a trend (based on 2003–2012 data) away from self-insurance among relatively small plans and toward self-insurance among relatively large plans.

EBIA Comment: Because the report uses 2012 data, it does not yet 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). Even in future years, the report’s reliance on Form 5500 filings probably will limit its usefulness in identifying self-insurance trends among small plans that are not required to file because they are unfunded, insured, or a combination of unfunded and insured. For more information, see EBIA’s Self-Insured Health Plans manual at Sections IV.B (“Why Self-Insure: 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 upcoming web seminar, “Self-Insuring Your Health Plan.”

Contributing Editors: EBIA Staff.

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