Brown & Brown, Inc. · NYSE:BRO
Brown & Brown — Health Benefit Plans and Medicare Webinar (June 2025)
35 slides from Brown & Brown's conference presentation, Jun 19, 2025
Slide 1: This Webinar Will Start Momentarily
This Webinar Will Start Momentarily. Thank you for joining us!
Slide 2: Health Benefit Plans and Medicare
Health Benefit Plans and Medicare JUNE 19, 2025 Presented By: Christopher Bao and Cindy Niesen Presented by the Regulatory and Legislative Strategy Group
Slide 3: Disclaimer
DISCLAIMER Brown & Brown, Inc. and all its affiliates, do not provide legal, regulatory or tax guidance, or advice. If legal advice, counsel or representation is needed, the services of a legal professional should be sought. The information in this document is intended to provide a general overview
Slide 4: Presentation Agenda
1 Medicare Basics Presentation Agenda 2 Medicare Integration with Group Health Plans HSA Eligibility, COBRA and Midyear 3 Elections Medicare Part D Prescription Drug 4 Coverage Disclosure Requirements 5 Wrap-Up BROW N & BROW N | 4
Slide 5: Medicare Basics
01 01 Medicare Basics
Slide 6: What Is Medicare?
What Is Medicare? Medicare is the federal health insurance program for: • People aged 65 and older • Certain younger people with disabilities • People with End-Stage Renal Disease (permanent kidney failure requiring dialysis or a transplant, sometimes called ESRD) Eligibility and enrollment will var
Slide 7: Medicare Coverage Types
Medicare Coverage Types PART A PART B PART C PART D HOSPITALIZATION GENERAL MEDICAL MEDICARE ADVANTAGE PRESCRIPTION DRUG • Eligible hospital • Inpatient and • Same coverage as Parts • Voluntary outpatient expenses outpatient medical A and B plus additional prescription drug benefit services and doct
Slide 8: Integration with Group Health Plans
Medicare Integration 02 with Group Health Plans
Slide 9: Entitlement
Medicare Entitlement
Slide 10: Eligibility, Enrollment and Entitlement
Eligibility, Enrollment and Entitlement DEFINITIONS ELIGIBLE ENROLLED ENTITLED The individual qualifies The individual has The individual has enrolled for Medicare coverage, completed the necessary in and is entitled to claim but may or may not be steps to obtain coverage benefits from Medicare enro
Slide 11: Secondary Payer Rules
Medicare Secondary Payer Rules
Slide 12: Medicare Secondary Payer (MSP) Rules
Medicare Secondary Payer (MSP) Rules D O E S M E D I C A R E E L I G I B I L I T Y O R E N T I T L E M E N T A F F E C T G R O U P H E A LT H P L A N ELIGIBILITY? • Will depend on the terms of the group health plan, which must comply with the MSP rules (if applicable) • MSP rules apply to private-se
Slide 13: Medicare Secondary Payer (MSP) Rules
Medicare Secondary Payer (MSP) Rules TA K I N G I N T O A C C O U N T M E D I C A R E E L I G I B I L I T Y O R E N T I T L E M E N T Group health plans subject to MSP rules may not “take into account” an individual's eligibility for, or entitlement to, Medicare (either based upon the individual’s a
Slide 14: Medicare Secondary Payer (MSP) Rules
Medicare Secondary Payer (MSP) Rules P R O H I B I T I O N A G A I N S T C E R TA I N I N C E N T I V E S / D I S I N C E N T I V E S W H E N E N R O L L I N G I N G R O U P H E A LT H P L A N • Employers are also prohibited from offering Medicare beneficiaries financial rewards or other benefits as
Slide 15: Medicare Secondary Payer (MSP) Rules
Medicare Secondary Payer (MSP) Rules OFFERING EQUAL BENEFITS FOR OLDER AND YOUNGER EMPLOYEES/SPOUSES • Group health plans must provide employees/spouses age 65+ with the same benefits under the same conditions provided to employees/spouses under age 65 • The requirement applies regardless of whether
Slide 16: Coordination of Benefits
Coordination of Benefits
Slide 17: Coordination of Benefits Under MSP Rules
Coordination of Benefits Under MSP Rules W I L L M E D I C A R E O R T H E G R O U P H E A LT H P L A N / P O L I C Y PAY F I R S T ? • When coverage is available for a service or item under more than one health plan/insurance policy for the same underlying claim for benefits, the coordination of be
Slide 18: Coordination of Benefits Under MSP Rules
Coordination of Benefits Under MSP Rules Age-Based Medicare entitlement + coverage due Disability-Based Medicare entitlement + retiree health to current employment status coverage or COBRA • Employer has 20+ employees = GHP primary payer • Medicare primary payer • Employer fewer than 20 employees =
Slide 19: HSAs, COBRA and Midyear Elections
HSAs, COBRA and 03 Midyear Elections
Slide 20: Health Savings Account (HSA) Eligibility
Health Savings Account (HSA) Eligibility DOES MEDICARE ENTITLEMENT AFFECT HSA ELIGIBILITY? • To contribute to an HSA, you must be (1) enrolled in an HSA-eligible HDHP, and (2) have no other disqualifying coverage. Medicare is considered “other disqualifying coverage” if an individual is enrolled in
Slide 21: Medicare and COBRA Continuation Coverage
Medicare and COBRA Continuation Coverage IS MEDICARE ENTITLEMENT A COBRA QUALIFYING EVENT? Second Qualifying Event for Spouse/Dependent • Covered employee’s Medicare • Due to MSP rules, Medicare entitlement will rarely be a entitlement is a triggering event in the second qualifying event since it wo
Slide 22: Medicare and COBRA Continuation Coverage
Medicare and COBRA Continuation Coverage C A N A P L A N T E R M I N AT E C O B R A C O V E R A G E D U E T O M E D I C A R E E N T I T L E M E N T ? Depends on the timing between the COBRA election and Medicare entitlement. COBRA election before Medicare entitlement • The plan may terminate the qua
Slide 23: Medicare and Midyear Election Changes
Medicare and Midyear Election Changes WILL MEDICARE ENTITLEMENT ALLOW FOR A MIDYEAR ELECTION CHANGE? Medicare entitlement is a permitted status change event • If plan allows, if an employee, spouse or dependent is under Code Section 125 covered under an employer’s health plan and enrolls in Medicare
Slide 24: Part D Prescription Drug Coverage Disclosure Requirements
Medicare Part D Prescription Drug 04 Coverage Disclosure Requirements
Slide 25: Medicare Part D – Background Information
Medicare Part D – Background Information Inflation Reduction Act Impact on Group Health Plans Inflation Reduction Act (IRA) - Changes to Medicare These updated parameters will increase the actuarial value Part D effective January 1, 2025: of Medicare Part D prescription drug coverage used to determi
Slide 26: Determining Creditable Coverage Status
Determining Creditable Coverage Status Different Methods for Determining Whether the GHP is Creditable vs. Non-Creditable Guidance includes three methods for determining whether a group health plan’s drug benefits are creditable: 1 2 3 Actuarial Determination Simplified Determination Revised Simplif
Slide 27: Determining Creditable Coverage Status
Determining Creditable Coverage Status A P P L I C AT I O N O F T H E S I M P L I F I E D D E T E R M I N AT I O N M E T H O D A N D T H E R E V I S E D S I M P L I F I E D D E T E R M I N AT I O N M E T H O D Simplified Determination Method The current Simplified Determination method may only be ut
Slide 28: Simplified Determination Method
Simplified Determination Method The 2009 (current) Simplified Determination method guidance includes two categories for determining whether a group health plan’s drug benefits are creditable, depending on whether the plan is considered an Integrated or Non-Integrated Plan: Integrated Plans Non-integ
Slide 29: Simplified Determination Method
Simplified Determination Method CURRENT (2009) METHODOLOGY 2 0 2 6 U P D AT E D M E T H O D O L O G Y Integrated Plans Non-integrated Plans (Revised Simplified Determination Method) Provides reasonable coverage for brand name and 1 (1) Coverage for brand and generic Rx Coverage for brand and generic
Slide 30: Part D Creditable/Non-Creditable Coverage Notice
Medicare Part D Creditable/Non-Creditable Coverage Notice DISCLOSURE TO INDIVIDUALS • Requirement applies to GHP sponsors that provide • Disclosure must be provided annually to all participants or, prescription drug coverage to Medicare Part D eligible alternatively — individuals » Prior to a partic
Slide 31: Part D Creditable/Non-Creditable Coverage Notice
Medicare Part D Creditable/Non-Creditable Coverage Notice DISCLOSURE TO CMS • Group health plans must disclose to CMS the creditable or non-creditable coverage status of their prescription drug plan • Requirement applies to GHP sponsors that provide prescription drug coverage to Medicare Part D elig
Slide 32: Wrap-Up
05 Wrap-Up
Slide 33: Key Considerations for Plan Sponsors
Key Considerations for Plan Sponsors • Only employers not subject to the MSP rules may impose eligibility or coverage restrictions based on the age/disability-based Medicare entitlement of a current employee (or their spouse/family member) » Note: employers must ensure any restrictions do not violat
Slide 34: HRCI and SHRM Credits
HRCI and SHRM Credits This Program, ID No. 700398 has been approved for 1.00 HR (General) recertification credit hours toward aPHR , aPHRi , PHR®, PHRca®, SPHR®, GPHR®, PHRi and SPHRi recertification through HR Certification Institute® (HRCI®). Brown & Brown is recognized by SHRM to offer Profession
Slide 35: Find your solution at BBrown.com
Find your solution at BBrown.com DISCLAIMER: Brown & Brown, Inc. and all its affiliates, do not provide legal, regulatory or tax guidance, or advice. If legal advice counsel or representation is needed, the services of a legal professional should be sought. The information in this document is intend
Brown & Brown — Health Benefit Plans and Medicare Webinar (June 2025) on 6ix