We’ve promised to provide more information regarding TranscendAHP 2020 plan renewals. Here are the important details to review and take note on – Despite Transcends best effort, there is not an apparent path forward for the current TranscendAHP program. All groups and sole proprietors must transition back to their prior-to-Transcend rating structure; Blue Cross® Blue Shield® of Michigan or Blue Care Network small group and community rating or an individual plan with a January 1, 2020, effective date of coverage. All claims with a December 31, 2019, or earlier date of service will be honored under the terms of the contract and plan selected with Transcend. For more details, please see below.
We want to make transitioning to a Blue Cross Blue Shield of Michigan or Blue Care Network plan as simple as possible! BCBSM is working on steps that will allow for moving groups back to an appropriate rating through a more streamlined approach with reducing the paperwork and underwriting process for Transcend AHP clients. Please connect with your Agent for more details.
DECISION BACKGROUND AND DETAILS
Over the last several months, Transcend has been working with our legal counsel, the Department of Labor (DOL), and Blue Cross Blue Shield of Michigan in the hope of finding a path forward for our current Association Health Plan (AHP) TranscendAHP. In a lawsuit known as New York vs. Department of Labor, in March of 2019, the D.C. Circuit court vacated many of the Department of Labor regulations that allowed what became known as Pathway 2 AHPs. TranscendAHP is a Pathway 2 AHP.
- In late March of 2019, the decision in New York vs. Department of Labor was made public.
- On April 26, 2019, the DOL appealed the decision and asked that the case be heard on an expedited basis. All parties agreed to this.
- Through our national AHP association, Transcend participated in the submission of an Amicus Brief (friend of the court) outlining the importance of group purchasing of health insurance for the small business community.
- The DOL provided a memo of non-enforcement on April 29, 2019, meaning that current Pathway 2 AHPs could continue operating until the end of their plan year.
- TranscendAHP’s plan year expires on December 31, 2019.
The DOL and all interested parties hoped that because so many AHPs operated on a calendar year, the case would be concluded before the end of 2019. However, we now know that the judges will not be selected until later this month, the oral arguments will not be heard until November 14, 2019, and the case will not be decided until, most likely, sometime in the first quarter of 2020. So much for expedited.
We had hoped the DOL would extend the non-enforcement period. However, we learned that the attorneys at the Department of Justice would not allow this, nor, due to the wording of the DOL non-enforcement memo, can we extend our plan year. Therefore, TranscendAHP will end at the conclusion of its plan year on December 31, 2019.
To say that the lawsuit and all that follows is political would be a gross understatement. The 11 attorneys general who brought the lawsuit are from states that already prohibit the group purchasing of health insurance by small businesses and individuals in their states. Please see this for what it is: an attempt by these 11 AGs to dictate to the rest of the country what national and individual state rules must be regarding small group health insurance. It is also an attempt to preserve many of the provisions of the Affordable Care Act, including those that result in many small businesses paying more for their health plans than otherwise might be required. TranscendAHP proved that there is a way to purchase high-quality health insurance for small businesses at a lower rate. New York vs. Department of Labor takes that opportunity off the table – at least for the time being.
Transcend is closely monitoring the possible outcomes in New York vs. Department of Labor. The appeals court could overturn the lower court ruling and allow Pathway 2 AHPs to continue. The court could also rule that Pathway 2 AHPs can continue with modifications, or the court could uphold the lower court ruling. Additionally, we are in the preliminary review stage and looking at rules which are not impacted by the court’s decision. As things become clearer, we will provide more information.
We appreciate your confidence in Transcend. As a thank you, we are extending all Transcend memberships through the end of 2020 for FREE keeping your customers eligible for other Transcend products and services currently under review, including Association Retirement Plans, attendance at webinars and our small business conference planned for early 2020.
The decisions made in Washington regarding group purchasing of health insurance are infuriating, but Transcend will continue. New York vs. Department of Labor is a perfect example of why small businesses need a voice in the decision-making process. Over the past several months, we have come to know many of the most important people nationally in the discussion of group purchasing via Association Health Plans. These connections will prove valuable in the future. Because we represent the interest of small businesses by helping them through daily business life, with a primary focus on their human resources needs, compliance solutions, and having the right resources to thrive in the Michigan business community, we must continue.
For many small businesses, the current health insurance landscape provides you and your employees with limited choices and flexibility. TranscendAHP was created as a health insurance solution that pools members together with the benefit of providing lower premiums and expanded benefits that currently only large businesses can obtain.
TranscendAHP allows small businesses to attract and retain top talent by offering a robust health insurance package with affordable rates.
To provide you with a more competitive set of solutions, Transcend has collaborated with Blue Cross® Blue Shield® of Michigan and Blue Care Network to offer a multiple employer welfare arrangement designed as a fully-insured benefit option for businesses with 50 or fewer enrolled contracts, including sole proprietors.
TranscendAHP is open to all independent insurance agents, please speak to your agent for a quote.
Advantages of an Association Health Plan:
- Access to an exclusive menu of health insurance plan options from BCBSM and BCN, many of which are not available to small business owners outside of the Association Health Plan. All plans have been selected to appeal to the varying needs of Michigan small business owners.
- Access to the vast BCBSM and BCN network of physicians and hospitals.
- Special pricing that could lower your premiums.
- You continue to use the independent insurance agent of your choosing.
- Enhanced billing, enrollment and customer service.
TranscendAHP is a product offering by Transcend, a member-based association that alleviates the need for Associations and Chambers to administer their own health care plan. TranscendAHP, powered by AHP Management Solutions, provides billing, enrollment and plan maintenance services for groups with 50 or fewer enrolled contracts.
AHP Management Solutions maintains the quote to enroll process to ensure a seamless member experience. As the agent, you will have the opportunity to offer the group a selection of 20 different Blue Cross® Blue Shield® of Michigan and Blue Care Network plan options, which dependent upon group size, will allow the group to offer up to three plan designs to their employees. To view the TranscendAHP product menu, click here.
Working with AHP Management Solutions, which is operationally serviced by TGG Solutions means shorter lead times and faster processing speeds. Together they provide enrollment and processing service and a single, consolidated bill for your members’ dues, medical, dental and vision plans. To better understand the relationship between Transcend, AHP Management Solutions and TGG Solutions, click here.
Click here for a list of frequently asked questions.
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