More than just words.
As you may remember, health savings accounts were created by U.S. Medicare legislation in 2003 as a tool to reduce healthcare costs. HSAs allow employees and their employers to contribute pre-tax money to pay for future medical expenses. The accounts belong to the employees, who can keep them even if they lose or change jobs. Money invested in the accounts can be carried over from year to year until needed or converted to a retirement fund.
To be eligible for an HSA, an employee must be covered by a "high deductible health plan" (HDHP) but cannot be covered by any other health plan, except for a few" specific exceptions. Earlier this year, the U.S. Treasury Department questioned whether EAPs are health plans. If so, they could not co-exist in an organization with HSAs. Since HSAs are expected to be highly popular, heavily marketed, and appealing to employers as a healthcare cost-containment tool, defining EAPs as health plans would represent a significant threat to the EAP profession in the United States and could lead to companies eliminating their EAPs.
In response to this threat, EAPA submitted a statement to the Treasury Department describing in detail why EAPs are more appropriately defined as workplace services than as health plans. In addition to citing the EAPA definition of employee assistance (including the EAP Core Technology functions), the statement noted that "one of the significant benefits of an EAP is its ability to help individuals sort out the healthcare from the non-healthcare issues and refer the individuals to appropriate multiple resources for needed assistance." EAPA's statement pointed out the following:
EAPs provide significant services to work organizations beyond those provided to individual employees and family members. In carrying out the core functions noted above, EAPs have proved invaluable in helping organizations prevent and respond to workplace violence; respond to disasters and other critical incidents: manage the disruption associated with mergers, acquisitions, or downsizing; improve workplace safety: increase employee morale; and reduce absenteeism, mistakes, and healthcare costs.
Based on EAPAs statement and input from many individual EA professionals and allied associations, the Treasury Department issued guidelines in late July confirming that eligibility for an EAP does not preclude eligibility for an HSA as long as the EAP "does not provide significant benefits in the nature of medical care or treatment." The Treasury guidelines also included this clarifying example:
An employer off-ere a program that provides employees with benefits under an EAE regardless of enrollment in a health plan. The EAP is specifically designed to assist the employer in improving productivity by helping employees identify and resolve concerns that affect job performance and the work environment. The benefits consist primarily of free or low-cost confidential short-term counseling to identify an employee's problem that may affect job performance and, when appropriate, referrals to an outside organization, facility or program to assist the employee in resolving the problem. The issues addressed during the short-term counseling include, but are not limited to, substance abuse, alcoholism, mental health or emotional disorders, financial or legal difficulties, and dependent care needs. This EAP is not a "health plan" under section 223(c)(1) because it does not provide significant benefits in the nature of medical care or treatment.
It is noteworthy that the Treasury guidance does not base its conclusion on the number of sessions an EAP might offer (although it does refer to "short-term counseling"). The Treasury, Department's approach is in line with EAPA's position that the important dimension is the purpose of sessions or contacts with employees, not the number of sessions or contacts.
The HSA issue is a clear example of the importance of being consistent, precise, and thoughtful in our use of professional terminology and the potential consequences of failing to do so. Many in our profession use language such as "utilization rate," "outcome," "network provider," and other terms less than rigorously These are not just words; they are part of our professional nomenclature. We should define, describe, and apply them carefully.
John Maynard is chief executive officer of the Employee Assistance Professionals Association. Contact him by e-mail at firstname.lastname@example.org.
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|Title Annotation:||employees-health savings accounts|
|Publication:||The Journal of Employee Assistance|
|Date:||Dec 1, 2004|
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