We need some industry leadership
Dave Patriarche
Sailor, Employee Benefits Specialist, Association Founder, Educator, Expert Witness, Associate Film Producer & Bestselling Author
As things start to slowly return to a new normal, we are seeing service such as massage, dental and other medical services start to open up.
I’ve polled my dental surgeon, dental hygenist and dentist friends and they are all back at it and ramping up pretty fast. Still, they are seeing fewer patients per day, and a long way from normal.
With this increased usage comes claims. With the claims, come questions from employees and I am expecting lots in the coming months with most being about COVID surcharges.
Generally, extra charges over the Reasonable & Customary (R&C) fees, and over provincial dental fee guides are not eligible for reimbursement by plans. This is to protect benefit plans from abuse and overcharging, thereby keeping them affordable. The Ontario Dental Association (ODA)(and presumably others) have added PPE codes to their fee guide in preparation for the expected increased costs being borne by their members. The problem we have is that we are still waiting for the CRA to see if the claims can be reimbursed by benefit plans.
Currently personal protective equipment is NOT an eligible medical expense (think work boots, welding gloves & shields, non-prescription safety glasses, hard hats etc.) so we would need to have CRA make some changes before plans would be allowed to pay them (assuming employers wanted that).
I mention this issue as employees will be asking their employers for help with this in the coming months. It is not as simple as asking us for an exception, or running all of these amounts (if over 10% of spend) through an HSA, as it could be offside and potentially make plans taxable. What we need is some clear direction...
- From the CRA: Can medically related PPE be reimbursed by benefit plans (therefore HSA's and also eligible for the METC) in a non-taxable manner?
- From Insurers: Will you be able to handle these charges (i.e. the new fee guide codes etc.) if they are eligible? and will it be an option for employers?
- From the CLHIA: Why has this not already been investigated and publicly communicated, as all insurers would be dealing with the same taxation issue and hence response?
Please add your comments, forward to Canadian insurers, and to anyone you know at the CRA and CLHIA. Let's get in front of this, not lag behind again. Thanks
Sailor, Employee Benefits Specialist, Association Founder, Educator, Expert Witness, Associate Film Producer & Bestselling Author
4 年I love this note clipped from myHSA "Benefit providers must be nimble. Upon reopening, dental offices began charging a PPE cost while many insurers remain ill-equipped for surprise costs bound within rigid plan designs. An HSA can pay for these if 90% of the total costs are eligible dental costs." Great to see solutions rather than silence. Good on Steven McEwan, CEBS, ISCEBS Fellow ,Tim Kane and the team.
Executive Vice President, HUB International
4 年I am curious how you state PPE is used more often. How can it be more often than 100% of the time. I have never been in a dental office without seeing PPE equipment used. And 5-7 times more expensive? Based on what? Maybe 20-30% more expensive due to supply issues but this will be straightened out in short order. If we are to believe that businesses should be able to surcharge because of CoVid, that would mean every service should dramatically more expensive. Should we pay twice as much for a vehicle because auto sales plummeted over 50% ? Many businesses are under extreme duress and will continue to be so under the weight of extended uncertainty. It is inappropriate for a benefit plan (the plan sponsor and employee who share the cost to fund) to be the vehicle to make another business whole. The cost of PPE per patient visit would be modest (1-$2 at most.
RB Financial Rick Bashista , BA, RHU Financial Planning Services, Employee Benefits
4 年Well stated. An obvious high urgency issue.
Senior Benefits Consultant, Benefits Policy Governance & Appeals, Total Compensation Strategies at Ontario Government
4 年A very legitimate concern, especially since this is unprecedented utilization of PPE and scope of cost. My friends in the Dental industry have confirmed that each individual Dental office/owner is providing and covering the cost for their staff, including contract Hygienists, with all the necessary equipment. Individual business “fees” to recover their cost may be passed onto the client, but this should become an industry standard approach. We all wait to see this unfold, thanks Dave for raising it.