Justice for lay employees – this was the
purpose of the Denominational Health Plan passed in 2009 (Resolution
A177). After all, we have passed
resolutions calling for universal health care coverage in the U.S. – why not
take the first step and provide it to our own employees? Most of our clergy (at least those with
full-time positions) are covered; it is the lay employees that are often left
out of our benefit structures.
Resolution A177 attempts to remedy this injustice.
It seems, however, that it is easier to call
for justice when the payment is coming out of someone else’s pockets than it is
to do justice when we have to pay for it ourselves. The Denominational Health Plan has caused a
lot of anxiety because it increases employee benefit costs at a time of very
tight budgets.
To date, a number of resolutions have been
proposed to modify the Denominational Health Plan, which was passed in 2009. I
am married to an actuary, Tom Snook, who is a Principal specializing in health
insurance with the international actuarial consulting firm, Milliman Inc. Tom
has helped me understand some of the economics of health insurance which are
relevant to this health plan, and which I would like to share with you.
To begin, I’ll review the requirements of the
2009 DHP legislation:
- The DHP ensures parity between health insurance benefits offered to clergy and lay employees, requiring that the same benefits be offered to both, as long as they work 1,500 hours or more per year (i.e., ¾ time or more).
- The DHP requires that health insurance be purchased from the Church Pension Group’s Episcopal Medical Trust. The Medical Trust is not a direct provider of health insurance; instead, it negotiates with providers such as Blue Cross, Aetna, etc., to come up with plans for each region of the country.
- The 2009 legislation asks dioceses to come up with specific regulations for implementing the plan, including questions of whether employees of diocesan schools and other non-church organizations must be included, how much of the cost the employee is required to share, whether domestic partner benefits must be included, etc.
- The DHP comes into effect on Jan. 1, 2013.
Because the requirement to cover lay employees
equally with clergy employees promises to cost many congregations money, the
plan has resulted in some controversy.
Proposals to modify the DHP requirements are in the works, including:
- Several proposals to delay the DHP’s implementation;
- Several proposals to allow insurance to be purchased from other providers than the CPG Medical Trust;
- Several proposals that require equity between geographic regions of the country; and
- A proposal from the Diocese of Olympia (C047), which I’ll get to later.
Taking these categories one at a time:
(1) Delay in implementation – I imagine
the goal here is to simply buy time before congregations have to pony up more
money. Is the hope that the recession
will end before we have to come up with more money, that people with deep
pockets will start flooding into our congregations between 2013 and 2016, that
we who have to run stewardship campaigns will have retired before the plan
comes into effect, or some other forlorn hope?
Is it true that justice delayed is justice denied? I am not sure what we hope to gain here. But I believe that a delay could result in
negative economic consequences for all of us – read on to understand more.
In addition, please note that the new
Healthcare Reform law (if upheld) could impose penalties beginning in 2014 on
employers who have 50 or more employees and who don’t provide adequate
insurance. (Click Here for info.) Most parishes do not have 50 employees, but
this penalty could affect dioceses, which are the legal employers of all
mission congregation employees. The
penalty is $2,000 per employee, so it could add up to $100,000 if there are 50
employees!
(2) Purchasing insurance from other
providers – I get the appeal here.
If you can go out and buy coverage more cheaply from someone else, why
pay more for the Denominational Health Plan?
To understand this, you have to understand a concept known as “adverse
selection.”
To illustrate: let’s say I have two lay
employees in my congregation: Gus and Janet.
Gus is 62 years old, has had numerous heart problems and a previous bout
with cancer. He is nearly uninsurable
under any individual plan, because the insurance premiums for him would be
astronomical. He comes to work for the
church for next to nothing, just for the benefit of being added to the group
health insurance plan provided by CPG, which saves him a fortune.
Janet, on the other hand, is 30 years old and
is in excellent health. She could get
health insurance far cheaper on her own, through an individual plan, than she
could get it through CPG. This is
because she is far healthier than the average CPG participant (since that
average person is, let’s say, a 58-year-old priest).
What is the natural result of allowing the
free market to operate on these two employees?
Janet, the younger, healthier employee, goes and buys her insurance
elsewhere. Gus, the older, sicker,
nearly uninsurable employee, buys his insurance through CPG.
Now multiply that effect throughout an entire
church of people who have their choice of where to buy health insurance. What do you end up with? CPG is covering a population full of older,
sicker employees, and CPG insurance is accordingly extremely expensive because
of the nature of its covered group. Note
that as it stands now, CPG covers mostly clergy employees, and as we all know,
clergy are, on the average, older than the general population. That means they are less healthy and more
expensive.
Other
things being equal, the general effect of requiring all employees, all
congregations, and all dioceses to be covered through CPG is that the average
cost of insurance through CPG goes down substantially. That’s
because the younger, cheaper folks can’t opt out, and they bring down the
average age of the whole group, saving money for everyone.
Yes, I know it sounds reasonable to allow
everyone to buy insurance where they want to.
It’s a free country, right? But
we need to understand the economic effects of the free market on the insurance
world before we start waving that free-market banner. (And, with 50 million uninsured Americans,
I’m not sure we can hold up the free market as a good health insurance
exemplar.)
(3) Requiring equity between different
geographical regions – again, this sounds like simple fairness. And sure, it is perfectly possible to
calculate health costs across the entire country and charge the average price
to everyone, everywhere. But wait. If you charge the average to everyone – some
people’s rates are going to go down. And
some people’s rates are going to go UP.
The fact is that health insurance premiums
vary in different geographic regions because the underlying health costs vary
across different geographic regions.
They vary a LOT. My husband Tom
was kind enough to point us to this report issued by his firm, Milliman, detailing
health costs across the country. I point
you specifically to Figure 6 on page 4.
If you live in New York City, Miami, Chicago, etc., you probably pay
health insurance costs above average for the country. Therefore equalizing premiums on a national
basis will mean your costs will go down.
However, if you live in Los Angeles, Denver,
Dallas, Seattle, Atlanta, or Phoenix, you probably pay health insurance costs
significantly below average. If we
equalize costs across the country, your premiums are going to go UP. In effect, you are going to be paying more in
order to subsidize the higher health costs in New York City and elsewhere.
Maybe this is a fair result, and maybe it is a
good thing for cheaper regions to subsidize more expensive ones. But we need to understand that this is the
result we would be voting for. I’m not saying it’s bad – you be the judge.
(4) The Olympia Proposal simply
requires that the DHP implementation deadline be suspended, with no new date
specified. It asks that dioceses be
given the flexibility to decide what is just and feasible in their own
contexts. Basically this proposal would
deep-six the entire Denominational Health Plan, making it go away forever,
saying goodbye to churchwide parity between clergy and lay employees (a justice
issue, remember?), and giving up any benefits that a churchwide plan could
provide.
I must say that the rationale provided in the explanation to the
Olympia resolution seems exceedingly weak to me. There are two reasons given, and basically
both reasons are: we can’t trust Episcopalians not to behave badly. First, according to the explanation:
“One unintended
consequence of Resolution A177 would be that vestries would tend to see the
minimum level established by the Diocese as an “accepted standard” and reduce
existing paid coverage to this level. Then
clergy and lay employees presently receiving more than this minimum
would see their benefits package reduced. In the case of clergy whose
congregations presently pay premiums for dependents this reduction could be
devastating. Yet any attempt by a vestry to transfer lost benefits to another
category of remuneration would go against the principle of equity.”
Really, guys, here I just have to
say – you don’t have to wipe out the entire DHP in order to solve this
problem. You don’t even have to bring
anything to the attention of General Convention. If this kind of finagling by vestries is a
problem in the Diocese of Olympia, my suggestion would be that Olympia pass a
diocesan resolution that prohibits vestries from doing it. Period, end of story.
The second rationale is this
one:
“Another unintended consequence of Resolution A177 would be that
financially hard-pressed congregations would tend to reduce the hours of lay
employees and clergy so that they fall under the threshold of eligibility.”
Again, I say, really? We want to wipe out the whole health care plan
because we fear that we might be tempted to artificially reduce an employee’s
work hours from 1,500 to 1,499 with the stroke of a pen? And your employees put up with that? And your Christian workplaces are willing to
do that to their employees?
I am a vicar (soon to be rector) in
a congregation myself, and I have to say that good employees are really hard to
find. I honestly cannot imagine
jeopardizing the ministry of a good employee by denying them benefits that they
deserve. Look, I know that the coming
health insurance rules are going to be hard for us to pay for. I just can’t stomach overturning these rules
– intended to provide justice and equity – on the basis that we can’t trust
each other not to be dishonest. Surely
The Episcopal Church can come up with a better vision than that.
Please note: +Greg Rickel, the
Bishop of Olympia, has shared with me (and given me permission to share with
you, Gentle Reader) that he does not support Olympia’s proposed resolution. Here is a direct quote from Bishop Rickel,
shared with his permission: “Time will not solve
any of the issues they bring up, and that is all this offers, for us to wait,
yet again, to do what we call on the rest of the world to do at every
convention.”
Money-Saving Proposals
As Bishop Rickel points out, The
Episcopal Church is good at proclaiming that other people should act justly,
but not so good at acting justly ourselves when it costs us money. I’ll let the
irony of that statement speak for itself.
But what should we do about the fact
that the DHP costs money, and we don’t have so much money these days? How should we encourage ministry to keep
happening, employees to keep being employed, and churches to keep running even
as we are mandating increased employment costs?
I think we can do this without
making any changes to the 2009 legislation at all. Let me point out that the DHP legislation
allows dioceses to set minimum coverage and cost-sharing guidelines for
churches. We don’t HAVE to pay 100% of a
very rich benefit plan and include the entire family of every employee, even
though that is often done for clergy under the current system. A diocese could create different rules.
In fact, although A177 does not
specifically allow it, a diocese could achieve parity for clergy and lay
employees over a period of years by creating a phase-in scheme. According to a CPG representative I
corresponded with, although A177 does not provide for a phase-in scheme on the
parity rules, the bishop of each diocese is the one responsible for enforcing
the canons of the church. Therefore, if
a diocesan scheme satisfies the bishop that it will achieve the goal of parity
in a reasonable period of time, CPG is not going to play compliance
police.
So, if I were going to create a
diocesan implementation plan, here is what I would propose to my bishop:
- “Grandfather” the benefits of every person who is already covered under a CPG plan. All those clergy with 100% family coverage of rich-benefit plans can keep their insurance, and newly added employees do not have to receive the same benefits.
- People working 1,500 hours or more who are not currently insured will have to be added to the plan as of 1/1/13 (unless they meet one of the exceptions, like coverage under a spousal plan).
- Newly added employees (new to the plan, or new to the job, either one) would have to have parity with each other – no difference between clergy and lay benefits.
- The diocese would decide on a minimum amount of coverage required. Churches could decide to provide more than the minimum, and employees could opt to pay for more than the minimum. Some of the options below could be chosen by the diocese as minimum standards in order to save money:
> The minimum could be a high-deductible, low-cost plan.
> It wouldn't have to include free family coverage.
> Employees could share part of the cost of premiums.
> Employees could pay more to upgrade any of the above.
> Note, this is similar to what many secular employers do.
- The grandfather clause takes care of the problem that we have a number of employees who are already covered under very rich benefit plans, and it is an economic hardship to give the same benefits to many newly added employees. Only newly added employees would be counted in the parity rules.
The result would be that over a
reasonable period of time, we would offer justice and parity to our lay
employees, without reducing benefits for people already covered under the old
system. Essentially, as clergy covered
under the old system retire, and new clergy come into the system, parity, and
justice, will be achieved. And it will
happen without the huge hit to parishes’ bottom line that many people fear is
coming next year. It’s a win-win. And it doesn’t require any new legislation at
all.