From AFSA Retiree V.P. Bill Farrand for all active and retired members:
Summary: This is not a call to action, but AFSA does want to make you
aware of an issue that could put Foreign Service retiree health benefits
at risk. As explained in detail below, a recent Office of Personnel
Management proposal could reduce prescription drug benefits for
Medicare-eligible retirees. AFSA is concerned that this OPM proposal to
change FEHBP benefits could be a first step in creating a separate
federal health benefits system for Medicare-eligible retirees. Because
of a recent Supreme Court action removing any legal impediment to
prevent employers from reducing or eliminating health benefits for these
retirees, such an OPM change could lead to negative impacts on Foreign
Service retirees. AFSA will keep monitoring this and will oppose any
changes that would harm our retirees. End of Summary.
Retiree Health Benefits at Risk
In a "call letter" sent March 11 to participating health plans, the
Office of Personnel Management outlined its 2009 goals for the Federal
Employee Health Benefit Program. The call letter signals the beginning
of negotiations for 2009 between health plans and OPM, which administers
the FEHBP.
OPM asked the health plans to submit proposals for a pilot program to
enhance coordination between FEHBP and Medicare. It also asked the
health plans to improve benefits for hard-of-hearing adults
(professional services and hearing aids).
OPM explained that the pilot program would be a sub-option for
Medicare-eligible enrollees within their existing plan options. Pilot
programs would feature “Medicare wrap-around benefits” or “premium
pass-through accounts”, so that a part of each retiree's FEHBP premium
could be used to pay for Medicare B, C, or D premiums. Participation in
the pilot program would be voluntary. Enrollees who opt for Medicare D
coverage would continue to pay the same premiums as they did for their
high, standard, or basic FEHBP options.
FEHBP health plans are now the primary insurers for prescription drugs;
FEHBP enrollees bear the cost of “co-pays” and deductibles. The OPM
proposal would designate Medicare D (the federal prescription drug
coverage program) as the primary insurer of those participating in the
pilot programs, and health carriers would become secondary, paying only
the deductibles and co-pays.
According to one knowledgeable source, OPM expects the pilot program to
enhance drug coverage for seniors while reducing the cost of
prescription drug coverage for health carriers. We note, however, that
at least one carrier has decided not to participate in the pilot program
on the grounds that it would result in offering retirees a limited list
of approved prescription drugs and require prior authorization. It
should be emphasized that FEHBP carriers now provide benefits that are
at least equal to or better than Medicare D and many provide
significantly superior benefits.
The proposal - which has not been subjected to public scrutiny or
detailed explanation - raises a number of questions.
First, how will FEHBP carriers and Medicare D plans negotiate
differences in formularies (the list of drugs a plan will pay for),
prior authorizations, the “doughnut” and other restrictions, both in
practice and administratively?
Second, what are the financial implications of coordinating benefits?
Who will pay the increasing costs for primary prescription drug
insurance coverage - Medicare D carriers, the federal government or,
ultimately, we the enrollees?
The Medicare Modernization and Improvement Act of 2003 is a cautionary
tale. It created Medicare Advantage Plans (or private commercial
alternatives to traditional Medicare) that combined Parts A, B, and C
within the traditional Medicare system. These private carriers now
receive government subsidies of about $1,000 per year per participant -
a matter of growing controversy.
The Supreme Court has denied review of a lower court decision ruling
that employers could reduce - or eliminate altogether - health benefits
for Medicare-eligible retirees. Like NARFE (the National Association of
Active and Retired Federal Employees), AFSA is wary of the OPM proposal
because it could open the door to establishing a separate FEHBP plan -
with lesser benefits and higher premiums costs - based either on age or
Medicare eligibility.
Before any pilot project is implemented, the OPM proposal must be
subjected to open explanation and public discussion of its effect on
federal retiree health benefits. FEHBP is the gold standard for health
benefits, including drug prescription coverage. Any OPM initiative that
would reduce benefits for retirees only would be unacceptable to AFSA.
We will keep you posted.
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