Array Bulletin: Service & Market Updates for May 2009

Array Health continues its focus on delivering superior service. We recently expanded our operations and support capabilities and refined our employee communication materials.

In this issue, we announce that Mitch Katz has joined Array Health as our Client Services Manager. We then take a look at what one local company, True North Service, has to say about our offering. We also discuss how HIPAA nondiscrimination regulations relate to Array Health's model.

Mitch Katz to Lead Array Health's Client Services

Array Health is pleased to announce that Mitch Katz has joined as Client Services Manager. Mitch has more than 20 years of experience in client service and customer support. As an operations professional at HarperCollins Publishers, Physician Micro Systems, and Smashing Ideas, Mitch has managed call centers, training centers, implementation groups and technical support teams, with a special emphasis on helping people take advantage of new technology.

For more information, please view our recent press release.

What Our Customers Are Saying

"Array Health provides THE health care solution for small business. From the plan selection tool to the all-in-one billing, Array Health makes it easy for us to provide health care coverage for our employees without having to join an expensive, restrictive group plan."

- Dan Deering, President of True North Service

For more information, please view the complete press release.

HRA Reimbursement of Individual Health Insurance and HIPAA

Brokers often ask how our model of using HRAs to reimburse for individual health insurance and other medical expenses applies to HIPAA nondiscrimination regulations, which prohibit discrimination based on health factors. Some brokers perceive the medical underwriting of individual policies as possibly conflicting with HIPAA nondiscrimination regulations.

Under Array Health's model, the HRA is the group benefits plan, not the individual insurance policies. Employees have access to their HRA dollars regardless of whether they choose to use their HRA money for insurance. Furthermore, because the HRA reimburses for all IRC Section §213(d) medical expenses, no employee is ever required to undergo medical underwriting to gain access to their plan dollars.

In its 2009 Consumer-Driven Health Care Guide, The Employee Benefits Institute of America (EBIA) commented on HRAs designed to reimburse both individual insurance premiums and other medical expenses:

"The final HIPAA nondiscrimination regulations specifically recognize that an HRA does not violate HIPAA's nondiscrimination requirements where 'employees who have participated in the plan for the same length of time are eligible for the same total benefit over that length of time (and the restriction on the maximum reimbursement amount is not directed at any individual participants or beneficiaries based on any health factor).' It would seem that the same conclusion could be reached for an HRA that reimburses individual health insurance premiums as well as other eligible medical expenses upon the request of any participant, because all employees who participate in the HRA for the same length of time would be eligible for the same total benefit over that period."

We are pleased that the compliance community is offering additional guidance on this model.

Sincerely,

Christopher Moneta

Director of Sales

1-800-640-7086