The latest rules imposed by the Regie de l’assurance maladie du Quebec(RAMQ)regarding Bill 130 will cause some difficulties for plan sponsors, according to a report from Morneau Sobeco.
The most important element is the coverage of children that ends when they turn 18 unless they are full-time students. Most group benefits plans stop providing coverage at age 21. Despite lobbying by the Canadian Life and Health Insurance Association, the RAMQ has decided to maintain a stand regarding the Act respecting prescription drug insurance and will not tolerate administrative relaxation of rules.
“Even if this requirement is valid only for the prescription drug portion of group benefits plans, we believe that it will be very difficult to administer plans having two definitions of children within one plan,” says the firm’s News & Views publication.
Consequently, many sponsors could be tempted to review the definition of a dependent child contained in their plan to lower the age at which coverage stop to age 18, both for prescription drugs and other types of coverage that apply to them.
This may be perceived negatively by plan members and the provision could also be contrary to what is provided in some labour agreements.
“Furthermore, in the case of national plans, applying a separate definition in other provinces will create a heavier administrative load and will make it more difficult to maintain a uniform plan across Canada,” states the publication. “This situation will then require good communication, particularly if employees transfer to Quebec.”
Morneau Sobeco proposes that sponsors who cover children until age 21, even if they are not students, is to maintain this coverage but to make the prescription drug portion of the plan a “second payer” plan starting at age 18 for those who are no longer students.
“This solution would have the advantage of minimizing the effects on the plan while complying with the requirements of the Act respecting prescription drug insurance.”
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