Employers and Health Care Reform

Employers and Health Care ReformEmployers and Health Care Reform

Ruselle W. Robinson, EsquireRuselle W. Robinson, EsquirePosternak Blankstein & Lund, LLPPosternak Blankstein & Lund, LLP

Boston, MABoston, MA(617) 973-6100(617) 973-6100

[email protected]@pbl.comwww.pbl.comwww.pbl.com

Posternak Blankstein & Lund, LLPosternak Blankstein & Lund, LLPP

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ContentsContentsBackgroundBackground 3 3

Insurance Reform—Group Health PlansInsurance Reform—Group Health Plans 9 9

Small Business Tax CreditSmall Business Tax Credit 1717

W-2 Reporting ChangesW-2 Reporting Changes 1919

Medicare Payroll Tax IncreaseMedicare Payroll Tax Increase 2020

Employer Responsibilities—January 1, 2013Employer Responsibilities—January 1, 2013 21 21

Individual MandateIndividual Mandate 2222

State Insurance ExchangesState Insurance Exchanges 2323

Employer Responsibilities—January 1, 2014Employer Responsibilities—January 1, 2014 2626

Cost Control MeasuresCost Control Measures 3030

Quality Improvement MeasuresQuality Improvement Measures 3131


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BackgroundBackground

Why Now For Health Care Reform?Why Now For Health Care Reform?

Implementation Rollout Implementation Rollout


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Why Now?Why Now? US has the most expensive health care system in the world, measured on a cost US has the most expensive health care system in the world, measured on a cost

per capita basis. In 2007, the US spent an estimated $7,290 per person on per capita basis. In 2007, the US spent an estimated $7,290 per person on health care. Australia was a distant second at $3,357 per person.health care. Australia was a distant second at $3,357 per person.

US health care spending is projected to rise from 16% of GDP in 2007 to 25% US health care spending is projected to rise from 16% of GDP in 2007 to 25% in 2025.in 2025.

The Federal Government’s share of health care expenditures is projected to The Federal Government’s share of health care expenditures is projected to exceed 50% of all health care expenditures in 2012 as public expenditures are exceed 50% of all health care expenditures in 2012 as public expenditures are rising at a more rapid rate than the private health care market.rising at a more rapid rate than the private health care market.

The US economy cannot afford the current rate of growth in health care The US economy cannot afford the current rate of growth in health care expenditures.expenditures.


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Other Problems With the U.S. SystemOther Problems With the U.S. System

The number of uninsured Americans is estimated to be more than 50 million in 2010, or more The number of uninsured Americans is estimated to be more than 50 million in 2010, or more than 16% of the population. The uninsured have worse health outcomes because they lack than 16% of the population. The uninsured have worse health outcomes because they lack regular access to the health care system.regular access to the health care system.

US trails other countries in measurable health care outcomes. CIA World Factbook (2009) US trails other countries in measurable health care outcomes. CIA World Factbook (2009) placed the US 49placed the US 49thth in overall life expectancy and 46 in overall life expectancy and 46 thth in infant mortality. in infant mortality.

Our large health care expenditures do not lead to overall better health outcomes. In other Our large health care expenditures do not lead to overall better health outcomes. In other words, we don’t get what we pay for.words, we don’t get what we pay for.


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Other Countries Have Met the Challenge of Providing Other Countries Have Met the Challenge of Providing Universal Coverage and Controlling CostsUniversal Coverage and Controlling Costs

1.1. England:England: Government Provides Direct Health Care Government Provides Direct Health Care

2.2. Canada:Canada: Single Payer SystemSingle Payer System

3.3. Germany:Germany: Regulation of Health InsuranceRegulation of Health Insurance

Each of these countries has developed a health care system with Each of these countries has developed a health care system with universal coverage and reasonable costs based upon its history and universal coverage and reasonable costs based upon its history and culture. culture.


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Goals of US Health Care ReformGoals of US Health Care Reform

Retain Structure of Present Health Care Insurance and Delivery SystemRetain Structure of Present Health Care Insurance and Delivery System

Keep Present Players in the System: Employers, Employees, Health Insurers, Keep Present Players in the System: Employers, Employees, Health Insurers, Government, Medical ProvidersGovernment, Medical Providers

Reduce Number of Uninsured Through Insurance ReformReduce Number of Uninsured Through Insurance Reform

Increase Affordability of Health Insurance for IndividualsIncrease Affordability of Health Insurance for Individuals

Reduce Overall Costs Reduce Overall Costs

Improve Quality of Care Within the Health Care Delivery SystemImprove Quality of Care Within the Health Care Delivery System


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ImplementationImplementation

Implemented in stages beginning January 1, 2010 and continuing into 2018 Implemented in stages beginning January 1, 2010 and continuing into 2018

Major Dates are September 23, 2010 and January 1, 2014 Major Dates are September 23, 2010 and January 1, 2014


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Primary Focus: Insurance Reform Primary Focus: Insurance Reform

Gives Incentives to Employers to Retain Health Insurance Benefit; Penalizes those Gives Incentives to Employers to Retain Health Insurance Benefit; Penalizes those Employers That Don’t Offer a Health Insurance Benefit Employers That Don’t Offer a Health Insurance Benefit

Expands Government Programs to Include Individuals Who Meet New Income Expands Government Programs to Include Individuals Who Meet New Income GuidelinesGuidelines

Sets up Insurance Exchanges for People Who Either do not Have or Cannot Afford Sets up Insurance Exchanges for People Who Either do not Have or Cannot Afford Employer-based Insurance and Are Not Eligible for Government-Sponsored Health Employer-based Insurance and Are Not Eligible for Government-Sponsored Health Insurance. Premiums Set on A Sliding Scale Based on IncomeInsurance. Premiums Set on A Sliding Scale Based on Income

Individuals Required to Have Health Insurance (Individual Mandate)Individuals Required to Have Health Insurance (Individual Mandate)


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Group Health PlansGroup Health Plans

Many of the mandates imposed by health care reform are imposed through Group Many of the mandates imposed by health care reform are imposed through Group Health Plan coverage requirements. A Group Health Plan is a program maintained Health Plan coverage requirements. A Group Health Plan is a program maintained by an employer or employee organization (e.g., a union) established and by an employer or employee organization (e.g., a union) established and maintained to provide medical care to employees and their dependents. Includes maintained to provide medical care to employees and their dependents. Includes fully-insured and self-insured plans.fully-insured and self-insured plans.

The definition does not include stand-alone supplemental health insurance plans, The definition does not include stand-alone supplemental health insurance plans, such as dental or vision plans, and does not include retiree-only health insurance such as dental or vision plans, and does not include retiree-only health insurance plans because retirees are not employees.plans because retirees are not employees.

Group health plans in effect on March 23, 2010 grandfathered from many of health Group health plans in effect on March 23, 2010 grandfathered from many of health care reform mandatescare reform mandates


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Grandfathered Group Health PlansGrandfathered Group Health Plans

Group Health Plans in effect on March 23, 2010 are grandfathered from some, but not all, health care reform mandates. A Group Health Plans in effect on March 23, 2010 are grandfathered from some, but not all, health care reform mandates. A group health plan must stay basically unchanged in the benefits it offers in order to remain grandfathered. group health plan must stay basically unchanged in the benefits it offers in order to remain grandfathered.

A grandfathered health plan must disclose its status in all plan materials describing plan benefits to participants and A grandfathered health plan must disclose its status in all plan materials describing plan benefits to participants and beneficiaries.beneficiaries.

All grandfathered health plans must maintain records that verify the plan complies with the rules to remain grandfathered.All grandfathered health plans must maintain records that verify the plan complies with the rules to remain grandfathered.

Special grandfather rules apply to fully-insured Group Health Plans maintained pursuant to collective bargaining agreements.Special grandfather rules apply to fully-insured Group Health Plans maintained pursuant to collective bargaining agreements.


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Grandfathered Group Health Plans, ContinuedGrandfathered Group Health Plans, Continued

Examples of changes a grandfathered group health plan can make and remain grandfathered:Examples of changes a grandfathered group health plan can make and remain grandfathered: Renew an insurance policy in effect on March 23, 2010Renew an insurance policy in effect on March 23, 2010 Change premium ratesChange premium rates Change third-party administratorChange third-party administrator Add family members of an individual employee Add family members of an individual employee Enroll new employeesEnroll new employees Change insurance carriers (without substantial changes to the existing plan)Change insurance carriers (without substantial changes to the existing plan)

Examples of changes that cause loss of grandfathered status:Examples of changes that cause loss of grandfathered status: Significantly increase costs or reduce benefits under the planSignificantly increase costs or reduce benefits under the plan Eliminate substantially all of the benefits to treat a particular conditionEliminate substantially all of the benefits to treat a particular condition Increase percentage cost-sharing requirements (e.g., co-pays) Increase percentage cost-sharing requirements (e.g., co-pays) Decrease the premium contribution rate of employer by more than 5%Decrease the premium contribution rate of employer by more than 5% Introduce or reduce an annual limit on benefitsIntroduce or reduce an annual limit on benefits


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September 23, 2010September 23, 2010

New Requirements Affecting All Group Health PlansNew Requirements Affecting All Group Health Plans

Apply to both fully-insured and self-insured plansApply to both fully-insured and self-insured plans

No lifetime limits on benefitsNo lifetime limits on benefits

No annual limits on benefits phased in 2010-2014No annual limits on benefits phased in 2010-2014

Prohibition on denying coverage or enrollment because of pre-existing Prohibition on denying coverage or enrollment because of pre-existing conditions now for under-19; for everyone January 1, 2014conditions now for under-19; for everyone January 1, 2014

Dependent children must be covered until the child turns 26. Children under Dependent children must be covered until the child turns 26. Children under 26 not presently enrolled must be given opportunity to enroll26 not presently enrolled must be given opportunity to enroll


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September 23, 2010September 23, 2010New Requirements Affecting All Group Health Plans, continuedNew Requirements Affecting All Group Health Plans, continued

No rescission of existing coverage unless due to fraud or misrepresentation of No rescission of existing coverage unless due to fraud or misrepresentation of material factmaterial fact

Health insurance issuers must spend at least 85% of premium revenue (large group Health insurance issuers must spend at least 85% of premium revenue (large group market/employers with 100 or more employees) as reimbursement for clinical market/employers with 100 or more employees) as reimbursement for clinical services or for activities that improve the quality of health care and (80% in small services or for activities that improve the quality of health care and (80% in small group market/employers with less than 100 employees), or provide a rebate to each group market/employers with less than 100 employees), or provide a rebate to each enrollee if the medical loss ratio is less (effective as of January 1, 2011) enrollee if the medical loss ratio is less (effective as of January 1, 2011)

Limited benefit plans can apply for waivers through 2013Limited benefit plans can apply for waivers through 2013


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September 23, 2010September 23, 2010New Requirements That Apply Only to Non-Grandfathered PlansNew Requirements That Apply Only to Non-Grandfathered Plans

Fully-insured plans cannot discriminate in favor of highly-paid employees when determining eligibility to Fully-insured plans cannot discriminate in favor of highly-paid employees when determining eligibility to participate or the level of benefits under the plan (self-insured plans already prohibited from discrimination participate or the level of benefits under the plan (self-insured plans already prohibited from discrimination by ERISA). Penalty for fully-insured plan is fine of $100 per day per employee discriminated against. by ERISA). Penalty for fully-insured plan is fine of $100 per day per employee discriminated against. Maximum penalty is $500,000. Maximum penalty is $500,000.

Employee taxed on value of excess benefitEmployee taxed on value of excess benefit ““Highly compensated” includes 5 highest paid officers, holder of 10% or more of company’s stock and highest paid 25% of all employeesHighly compensated” includes 5 highest paid officers, holder of 10% or more of company’s stock and highest paid 25% of all employees In general, the employer must offer the same benefits to all employees on the financial same terms (employee premium contribution, co-pays, In general, the employer must offer the same benefits to all employees on the financial same terms (employee premium contribution, co-pays,

deductibles)deductibles) Some companies are considering charging higher premiums to highly compensated individualsSome companies are considering charging higher premiums to highly compensated individuals

NOTE: IRS has postponed effective date of this requirement while it sorts out definition of NOTE: IRS has postponed effective date of this requirement while it sorts out definition of “discrimination”.“discrimination”.

““First Dollar” coverage required for immunizations, “evidence-based” preventive care for children and First Dollar” coverage required for immunizations, “evidence-based” preventive care for children and adolescents and for preventive care and screenings for women (e.g., mammograms). “First dollar” means adolescents and for preventive care and screenings for women (e.g., mammograms). “First dollar” means no deductibles or co-pays for the service. Intended to encourage the practice of preventive medicine.no deductibles or co-pays for the service. Intended to encourage the practice of preventive medicine.


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September 23, 2010September 23, 2010

Non-Grandfathered Plans, continuedNon-Grandfathered Plans, continued

Plans must establish internal claims and appeals process and have an Plans must establish internal claims and appeals process and have an external review process.external review process.

Patients must have right to choose primary care physicians from within a Patients must have right to choose primary care physicians from within a network, to access obstetrical and gynecological services without a referral network, to access obstetrical and gynecological services without a referral or authorization from another physician, and to access emergency services or authorization from another physician, and to access emergency services without prior authorization.without prior authorization.


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January 1, 2010January 1, 2010

Small Business Tax CreditSmall Business Tax Credit

Transitional credit effective beginning with 2010 tax year. Phased out when State Insurance Exchanges Transitional credit effective beginning with 2010 tax year. Phased out when State Insurance Exchanges come on line.come on line.

Available to employers with fewer than 25 full-time equivalent employees with average wages of less than Available to employers with fewer than 25 full-time equivalent employees with average wages of less than $50,000. A full-time equivalent equals 2,080 payroll hours.$50,000. A full-time equivalent equals 2,080 payroll hours.

The tax credit is on a sliding scale beginning with employers with 10 or fewer employees and average The tax credit is on a sliding scale beginning with employers with 10 or fewer employees and average wages of less than $25,000.wages of less than $25,000.

In 2010 through 2013, the employer can receive a tax credit of up to 35% of their premium contribution to In 2010 through 2013, the employer can receive a tax credit of up to 35% of their premium contribution to the company’s group health plan.the company’s group health plan.

Beginning in 2014, the employer may qualify for two years for a tax credit of up to 50% of their premium Beginning in 2014, the employer may qualify for two years for a tax credit of up to 50% of their premium contribution to the company’s group health plan.contribution to the company’s group health plan.


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Small Business Tax Credit, continuedSmall Business Tax Credit, continued

To qualify in 2010-2013, Employer must offer “qualified health plan” (not defined To qualify in 2010-2013, Employer must offer “qualified health plan” (not defined as of yet) and contribute at least 50% of the premium cost of the plan. In 2014, a as of yet) and contribute at least 50% of the premium cost of the plan. In 2014, a “qualified health plan” will be a plan offered through an Exchange.“qualified health plan” will be a plan offered through an Exchange.


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January 1, 2011January 1, 2011W-2 ReportingW-2 Reporting

Affects Grandfathered and Non-Grandfathered PlansAffects Grandfathered and Non-Grandfathered Plans

Beginning with 2011 tax year, every employer Beginning with 2011 tax year, every employer may voluntarilymay voluntarily report the report the aggregate cost (employer plus employee share) of the employer’s health aggregate cost (employer plus employee share) of the employer’s health insurance benefits on employee Form W-2s. Reporting is insurance benefits on employee Form W-2s. Reporting is requiredrequired for most for most employers beginning January 1, 2012. Effective date for employers issuing employers beginning January 1, 2012. Effective date for employers issuing fewer than 250 W-2s in 2011 will be later.fewer than 250 W-2s in 2011 will be later.

For fully-insured plans, total cost is total premium paid. For self-insured plans, For fully-insured plans, total cost is total premium paid. For self-insured plans, total cost is determined using formula similar to rules used for calculating total cost is determined using formula similar to rules used for calculating COBRA premiums. Includes medical insurance, dental and vision plans.COBRA premiums. Includes medical insurance, dental and vision plans.


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January 1, 2013January 1, 2013Medicare Payroll Tax IncreaseMedicare Payroll Tax Increase

Medicare Hospital Payroll tax increases by .9% on individuals that earn Medicare Hospital Payroll tax increases by .9% on individuals that earn over $200,000 and joint filers that earn over $250,000 (no indexing for over $200,000 and joint filers that earn over $250,000 (no indexing for inflation). inflation).

New Medicare tax of 3.8% on investment income for individuals that earn New Medicare tax of 3.8% on investment income for individuals that earn over $200,000 and joint filers that earn over $250,000 (no indexing for over $200,000 and joint filers that earn over $250,000 (no indexing for inflation)inflation)

Flexible spending account limited to $2,500 annually (indexed for Flexible spending account limited to $2,500 annually (indexed for inflation)inflation)


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Employer ResponsibilitiesEmployer Responsibilities

Employer must notify employee of existence of State Employer must notify employee of existence of State Insurance Exchanges and federal premium subsidies (both Insurance Exchanges and federal premium subsidies (both take effect January 1, 2014)take effect January 1, 2014)

Open enrollment for State Insurance Exchanges Open enrollment for State Insurance Exchanges


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January 1, 2014January 1, 2014Individual MandateIndividual Mandate

Individual must have minimum essential coverage for Individual must have minimum essential coverage for themselves and their dependents.themselves and their dependents.

Insurance can be obtained through Employer, an Exchange, Insurance can be obtained through Employer, an Exchange, or a government program such as Medicare and Medicaid.or a government program such as Medicare and Medicaid.

Individuals who don’t have insurance will pay a penalty.Individuals who don’t have insurance will pay a penalty.


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January 1, 2014January 1, 2014State Insurance ExchangesState Insurance Exchanges

Each state is required to establish an Exchange by this date. Federal Each state is required to establish an Exchange by this date. Federal government will set it up if a state fails to act. government will set it up if a state fails to act.

A health insurer seeking to participate in an Exchange must be approved A health insurer seeking to participate in an Exchange must be approved by that state as meeting certain criteria, including providing a set of by that state as meeting certain criteria, including providing a set of defined benefits and meeting cost-sharing requirements (i.e., deductibles defined benefits and meeting cost-sharing requirements (i.e., deductibles and co-pays). and co-pays).

The states generally will not regulate the premiums charged by insurers The states generally will not regulate the premiums charged by insurers

listed on their Exchanges.listed on their Exchanges.


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January 1, 2014January 1, 2014State Insurance ExchangesState Insurance Exchanges, , continuedcontinued

Eligibility for the Exchanges will be limited toEligibility for the Exchanges will be limited to:: Employees of companies with fewer Employees of companies with fewer thanthan 100 employees 100 employees Employees of companies that do not provide health Employees of companies that do not provide health

insuranceinsurance Self-employedSelf-employed UnemployedUnemployed Retired, but not eligible for MedicareRetired, but not eligible for Medicare Small businessesSmall businesses All business eligible after January 1, 2017 All business eligible after January 1, 2017


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State Insurance Exchanges, continuedState Insurance Exchanges, continued

Policies available on a sliding scale for individuals and families with Policies available on a sliding scale for individuals and families with subsidies available for households with income equal to 133-400% of subsidies available for households with income equal to 133-400% of federal poverty level (400% of federal poverty level=$88,000 for a family federal poverty level (400% of federal poverty level=$88,000 for a family of 4)of 4)


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January 1, 2014January 1, 2014Employer ResponsibilitiesEmployer Responsibilities

No legal obligation to provide health insuranceNo legal obligation to provide health insurance

““Large” employer can be penalized for not offering health care Large” employer can be penalized for not offering health care insurance benefit; for offering a health insurance benefit that insurance benefit; for offering a health insurance benefit that does not include “minimum essential coverage” (still to be does not include “minimum essential coverage” (still to be defined”); or for offering a health insurance benefit that is not defined”); or for offering a health insurance benefit that is not affordable to its employees.affordable to its employees.

Large employer means 50 or more full-time equivalent employeesLarge employer means 50 or more full-time equivalent employees Full-time is 30 hours or more per week on averageFull-time is 30 hours or more per week on average


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January 1, 2014January 1, 2014Employer Responsibilities, continuedEmployer Responsibilities, continued

Employers with more than 200 employees must automatically enroll their Employers with more than 200 employees must automatically enroll their eligible employees in a health insurance coverage option when they eligible employees in a health insurance coverage option when they become eligible. Employer must give employee a notice of enrollment and become eligible. Employer must give employee a notice of enrollment and opportunity to opt-out. The effective date for this requirement may be opportunity to opt-out. The effective date for this requirement may be delayed while the Department of Labor works on defining key terms (e.g., delayed while the Department of Labor works on defining key terms (e.g., full-time employee).full-time employee).

Health Insurance enrollment waiting period cannot exceed 90 days. Health Insurance enrollment waiting period cannot exceed 90 days.

Employers begin reporting of individual health insurance coverage to Employers begin reporting of individual health insurance coverage to Internal Revenue Service. Purpose is for enforcement of individual Internal Revenue Service. Purpose is for enforcement of individual mandate.mandate.


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January 1, 2014January 1, 2014Employer PenaltyEmployer Penalty

Employer liable for penalty if does not offer health insurance benefit, or if offered benefit Employer liable for penalty if does not offer health insurance benefit, or if offered benefit does not meet certain standards.does not meet certain standards.

Penalty if no health insurance benefit or insurance benefit does not provide “minimum Penalty if no health insurance benefit or insurance benefit does not provide “minimum essential coverage”:essential coverage”:

If one or more employees enrolls in an insurance exchange and qualifies for government subsidized policyIf one or more employees enrolls in an insurance exchange and qualifies for government subsidized policy Then, employer penalty equals $2,000 for each of its full-time employees (first 30 employees are exempt)Then, employer penalty equals $2,000 for each of its full-time employees (first 30 employees are exempt)

Penalty if health insurance benefit is not affordable:Penalty if health insurance benefit is not affordable: Employer offers health insurance benefit with minimum essential coverage, andEmployer offers health insurance benefit with minimum essential coverage, and If one or more employees enrolls in insurance exchange and qualifies for government subsidized policy because If one or more employees enrolls in insurance exchange and qualifies for government subsidized policy because

employee’s share of the premium for employer’s benefit exceeded 9.5% of household income, oremployee’s share of the premium for employer’s benefit exceeded 9.5% of household income, or the employer’s plan does not cover at least 60% of health care expensesthe employer’s plan does not cover at least 60% of health care expenses Then, employer penalty equals $3,000 for each full-time employee who receives a government subsidyThen, employer penalty equals $3,000 for each full-time employee who receives a government subsidy


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January 1, 2014January 1, 2014Employer Penalty, ContinuedEmployer Penalty, Continued

Employer can avoid penalty if:Employer can avoid penalty if:

The Employer provides a health care benefit with “minimum essential The Employer provides a health care benefit with “minimum essential coverage” coverage”

The Employer pays 60% or more of the cost of health care under its health The Employer pays 60% or more of the cost of health care under its health insurance plan, and insurance plan, and

The employee premium contribution does not exceed 9.5% of the employee’s The employee premium contribution does not exceed 9.5% of the employee’s household incomehousehold income

The Employer is not penalized unless an employee enrolls in an insurance The Employer is not penalized unless an employee enrolls in an insurance exchange and qualifies for subsidized coverageexchange and qualifies for subsidized coverage


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Cost Control MeasuresCost Control Measures

Reducing health care costs is a process that will take years to implement.Reducing health care costs is a process that will take years to implement.

Cost control elements of health care reform include the following:Cost control elements of health care reform include the following:

Contains measures against Medicare Fraud and AbuseContains measures against Medicare Fraud and Abuse Promotes electronic health care records, which reduce medical errors and improve Promotes electronic health care records, which reduce medical errors and improve

coordination of patient carecoordination of patient care Changes payment formulas for complex imaging studies to reduce paymentsChanges payment formulas for complex imaging studies to reduce payments Reduces subsidies for Medicare Advantage Plans (Part C)Reduces subsidies for Medicare Advantage Plans (Part C) Imposes excise tax on “Cadillac” health insurance plans (2018)Imposes excise tax on “Cadillac” health insurance plans (2018) Promotes integrated, patient-centered care model to reduce excesses of fee-for-Promotes integrated, patient-centered care model to reduce excesses of fee-for-

service payment systemservice payment system Funds research into “evidence-based care” so that patient care becomes more Funds research into “evidence-based care” so that patient care becomes more

standardized; goal is to reduce care that does not produce resultsstandardized; goal is to reduce care that does not produce results


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Quality Improvement MeasuresQuality Improvement Measures

Modifies payment system for hospitals and physicians to reward qualityModifies payment system for hospitals and physicians to reward quality Creates incentives to reduce hospital-acquired medical conditionsCreates incentives to reduce hospital-acquired medical conditions Creates incentives for hospitals to reduce readmissions for the same conditionCreates incentives for hospitals to reduce readmissions for the same condition Sets up reporting requirements for quality data, and offers financial incentives to cooperating Sets up reporting requirements for quality data, and offers financial incentives to cooperating

providersproviders Funds pilot program to create financial incentives to promote integrated patient care model Funds pilot program to create financial incentives to promote integrated patient care model

with a bundled paymentwith a bundled payment Orders creation of program offering shared savings for accountable care organizations with Orders creation of program offering shared savings for accountable care organizations with

primary care physicians at the centerprimary care physicians at the center

Employers and Health Care Reform

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