Group Insurance Commission
Administrative Bulletin FY13-01: Guidance Regarding Municipal Retiree Participation in the GIC Retiree Dental Plan
August 30, 2012
In keeping with recent changes in the law, the Group Insurance Commission (GIC) will be expanding its Retiree Dental Plan to include certain municipal retirees and survivors – specifically, retirees, survivors, and their dependents of municipalities that offer health insurance to their active and retired employees through the GIC. The purpose of this bulletin is to inform interested parties how the GIC will implement this expansion.
The FY13 budget added parallel provisions to each of the two statutes that allow municipalities to offer health insurance via the GIC. See M.G.L. c.32B, §§ 19(j) and 23(i), as amended by St. 2012, c. 139, §§ 66 and 67. A municipality that has transferred its employees, retirees, survivors, and dependents to the GIC for the purposes of providing health insurance may also offer GIC dental insurance to their retirees and surviving spouses, plus their dependents. Retirees and survivors of municipalities that administer health insurance other than through the GIC are not eligible for the GIC Retiree Dental Plan. The new laws specify that participants must pay one hundred percent of premiums, plus an administrative fee of up to 1 percent.
In Order for Retirees to Participate, Municipalities Must Opt In
Municipalities will have an important role in the administration of the Retiree Dental Plan for municipal retirees. Therefore, in order for a municipal retiree or survivor to enroll in the Retiree Dental Plan, the municipality must notify the GIC’s Executive Director of its intent to participate in the program. Municipal retirees and survivors who wish to enroll in the Retiree Dental Plan should contact their municipality to express their interest in the program.
Participating Municipalities. Municipal Employers that currently offer health insurance through the GIC to their active and retired employees pursuant to a Public Employee Committee (PEC) agreement, a § 21 panel order, or special legislation (Springfield, Lawrence), or that will do so as of January 1, 2013 (Orange, Peabody), must notify the GIC’s Executive Director in writing by December 1, 2012 if they wish to offer the GIC’s Retiree Dental Plan as of July 1, 2013. For Municipal Employers that do not opt in this year, these deadlines will repeat in future years (notice by a Municipal Employer by Dec. 1 for coverage the following July 1). Participating municipalities who opt in to the Retiree Dental Plan must do so for the remaining duration of their PEC agreement or order.
At the time that a currently participating Municipal Employer notifies the GIC that it will be extending its PEC agreement for another period of three or six years, the Municipal Employer should also inform the GIC in writing whether it intends to participate in the Retiree Dental Plan during that period. If the Municipal Employer has opted into the GIC Retiree Dental Plan and is silent on the subject at the time of renewal, the Municipal Employer will remain in the Retiree Dental Plan for the duration of the new agreement.
- Example. Town A is currently offering health insurance through the GIC, under the terms of a three-year PEC agreement that will expire on June 30, 2014. They want to offer the GIC Retiree Dental Plan. Town A’s Board of Selectmen should notify the GIC by Dec. 1, 2012 that they wish to opt in to the Retiree Dental Plan, effective July 1, 2013. That election will remain in effect until June 30, 2014 (and may be extended under any future PEC agreement).
Prospective Municipalities (coverage effective July 1, 2013 or later). At the time that a Municipal Employer notifies the GIC that it will be newly transferring its subscribers to the GIC pursuant to c. 32B, § 19 or 23, the Municipal Employer should also inform the GIC in writing whether it intends to opt into the Retiree Dental Plan for the duration of its PEC agreement or panel order. The same deadlines apply as for health coverage (December 1 for July 1 coverage, and July 1 for January 1 coverage). Municipal Employers that opt out at the first opportunity may still opt in at a later date, as described above for participating municipalities.
- Example. In November of 2013, Town B finalizes a § 19 Agreement with its PEC and notifies the GIC that it will be transferring its subscribers to the GIC for a three year period (July 1, 2014 – June 30, 2017). Town B may opt into the Retiree Dental Plan as of July 1, 2014 by notifying the GIC by Dec. 1, 2013 (the § 19 deadline). If Town B does not opt in as of Dec. 1, 2013, it has the same option the following Dec. 1.
GIC RMT / EGR Municipalities. Municipalities that participate and intend to remain in the GIC’s Retired Municipal Teacher (RMT) or Elderly Governmental Retiree (EGR) programs do not need to do anything. The GIC’s RMTs and EGRs will continue to be eligible for the Retiree Dental Plan, and are unaffected by the change in law or this bulletin.
During the GIC’s regular Annual Enrollment each spring (usually mid-April to early May), retirees and survivors from municipalities that have opted into the Retiree Dental Plan may enroll in the Retiree Dental Plan for coverage effective July 1. Except for new retirees and survivors, or with proof of involuntary loss of other non-GIC dental coverage, enrollment is only permitted during Annual Enrollment. The GIC will work with municipalities to enroll new retirees and survivors as they become eligible.
An eligible retiree or survivor may enroll in the Retiree Dental Plan without also enrolling in a health plan. However, dental-only coverage at the time of death will not qualify a retiree’s spouse to be eligible for subsequent GIC health coverage as a Surviving Spouse.
After July 1, 2013, former RMTs/EGRs in communities that have newly transferred all subscribers to the GIC per c. 32B, § 19 or 23, may remain enrolled in the GIC’s Retiree Dental Plan. They will be treated as continuing and not new enrollees, and their benefit limits do not reset.
- Example. RMT X, from Town C, is enrolled in the GIC’s Retiree Dental Plan. RMT X gets two cleanings, on Jan. 3, 2014 and June 25, 2014, thus reaching the limit of two cleanings per calendar year. On July 1, 2014, Town C transfers all active and retired employees to the GIC, as authorized by a PEC agreement. RMT X may remain in the GIC’s Retiree Dental Plan, but is not entitled to any more cleanings in 2014.
Municipalities who have decided to offer the GIC’s Retiree Dental Plan may later opt out of the plan on the same schedule as they may opt out of health insurance: that is, by notifying the GIC’s Executive Director by October 1 of the final fiscal year of their PEC agreement or panel order.
Eligible participants who voluntarily terminate their coverage in the Retiree Dental Plan may not later rejoin the plan, unless their termination was solely the result of their municipality’s decision to stop offering the GIC’s Retiree Dental Plan.
Premiums for the Retiree Dental Plan are established each year, effective July 1, by the Commission. The Commission has the option of adding an administrative fee of up to 1% of premiums. Retirees and survivors are responsible for the full cost of the premium and any administrative fee.
Allocation of Responsibilities
The GIC will develop communications materials as well as standard enrollment forms. Municipal Employers will collect enrollment forms and supporting documents from eligible retirees and survivors. The GIC makes the final determination of eligibility, all effective and termination dates, and all terms of the benefits offered through the Retiree Dental Plan.
A month in advance of each coverage month, Municipal Employers must collect premiums from enrolled participants. The GIC will bill Municipal Employers monthly for the full cost of premiums plus the administrative fee, and payment must be received at the GIC by the invoice due date. The GIC will send a monthly roster of enrollees to Municipal Employers, who must reconcile the list of enrollees with their own records and report discrepancies to the GIC.
Municipalities who opt into the Retiree Dental Plan must offer the GIC plan as their sole retiree dental coverage.
Required Municipal Initial Enrollment Data
Effective July 1, 2011
|Social Security Number||Social Security Number|
|First Name||Relationship (Dependent, Spouse, Former Spouse)|
|Middle Initial||First Name|
|Last Name||Middle Initial|
|Primary Address 1||Gender|
|Primary Address 2||Date of Birth|
|Primary Address 3||Primary Address 1 (if former spouse)|
|City||Primary Address 2 (if former spouse)|
|State||Primary Address 3 (if former spouse)|
|Zip code||City (if former spouse)|
|Zip plus 4||State (if former spouse)|
|Foreign City/Country||Zip Code (if former spouse)|
|Date of Birth||Zip plus 4 (if former spouse and available)|
|Date of Retirement (only if retired status)||Home phone area code (if former spouse and available)|
|Date into Service (only if active status)||Home phone number (if former spouse and available)|
|Status (Active, Retired, Survivor, COBRA)|
|Home phone area code (if available)|
|Home phone number (if available)|
|Business phone area code (if available)|
|Business phone number (if available)|
|Business phone extension (if available)|
|COBRA start date (only if COBRA status)|
|COBRA end date (only if COBRA status)|
|Hours worked (only if active status)|
|Department (only if active status)|
Supported File Formats
Excel comma separated file*
* file layouts on separate document
Municipal Requests for Utilization Data
Group Insurance Commission
Administrative Bulletin 14-02:Guidance Regarding Municipal Requests for Utilization Data
April 13, 2010, Revised: November 29, 2010; Revised: February 4, 2014
The purpose of this bulletin is to clarify and outline the parameters under which the Group Insurance Commission (GIC) will respond to written requests for enrollment and utilization data, pursuant to 805 CMR 8.06, from political subdivisions, as defined in M.G.L. c.32B s.2, that provide health insurance coverage through the GIC to its subscribers by acceptance of the Municipal Partnership Act, M.G.L. c.32B s. 19 and s. 21 and that are considering whether to remain inside the GIC. The parameters clarified and outlined herein also apply to requests for enrollment and utilization data made by Public Employee Committees (PEC) described in M.G.L. c. 32B, §§ 19(a) and 21(b). These data requests are for the sole purpose of determining whether a participating municipal employer and its subscribers in the GIC's health coverage program will continue to participate after their coverage interval of three or six years, as specified in their PEC agreement, expires. Requests for such data shall be made in the preceding or current fiscal year in which a given PEC agreement is open to negotiation, and such requests shall be limited to one request from a political subdivision and one request from a PEC in the preceding or current fiscal year in which a political subdivision is considering withdrawing from GIC coverage.
1) Political subdivisions and PECs requesting utilization data should assess the amount of time they will need to analyze data and conduct negotiations necessary before making a decision about whether to remain in the GIC. Such entities must submit their requests to the GIC at least 60 days before the data are to be provided to them to use in their decision-making process. In the event that a political subdivision and a PEC request data in the same year, the GIC will supply data for the same time period to both entities.
A request from a political subdivision for data must be made in writing and signed by the appropriate legal representative of the public authority, as defined in M.G.L. c.32B, § 2(a). In a City, the request must be signed by the City Manager or the Mayor, in a Town by the Chairman of the Board of Selectmen, and in a regional school district, by the Chairman of the Regional School District Committee. A request for data from a PEC must be made in writing, signed by a majority of representatives of the PEC, or by a weighted majority of representatives by membership in the PEC. The GIC will notify a political subdivision of a data request made by the associated PEC.
2) The GIC will provide three years of the following data to each requesting entity with more than 50 subscribers:
a. A monthly claims report consisting of the following data elements:
i. the subscriber count;
ii. the covered lives count;
iii. the total paid medical claims;
iv. the total paid prescription drug claims.
A yearly large loss report, i.e., for claimants who have incurred $25,000 or more paid claims in a given year, consisting of the following elements:
- the de-identified claimant diagnosis codes;
- the de-identified claimant total paid claims (medical and prescription drug).
3) Entities that have requested these data will be required to designate a single person to handle said data. The GIC will provide the de-identified Protected Health Information to the person identified by the requesting entity as authorized to receive such data as the GIC's Business Associate under the HIPAA Privacy Rule after said person signs the GIC's Business Associate Agreement (BAA), as most recently amended. The designated person must agree not to share these data with other parties, including municipal employees, PEC members and union personnel. The data may be shared with insurance brokers, benefits consultants, and health plans for the limited purpose of securing bids for the procurement of health insurance to the extent allowed by the applicable BAA. The GIC encourages political subdivisions and PECs to designate consultants as persons authorized to receive the data.
Please note: Medicare HMO data may not be available if such data have not been submitted to the GIC’s data vendor by the plan. Communities wanting such data should use the monthly premium as a substitute for actual cost (administrative costs are also not included in the data provided).
Elected Officials and Local Option Participants
Group Insurance Commission
Administrative Bulletin FY13-02: Guidance Regarding
Implementation of Regulatory Changes to Eligibility for Health Insurance
April 17, 2013
In regulations approved by the Commission on April 12, 2013, the Group Insurance Commission (GIC) revised its interpretation of c. 32B, §§ 19 and 23, with respect to the eligibility for health insurance through the GIC of municipal elected officials and certain other classes of employees. As soon as they are published by the Secretary of the Commonwealth, the regulations will become final. The GIC anticipates they will be published on May 10, and so will be in effect for the plan year starting July 1, 2013. The purpose of this bulletin is to inform interested parties how the GIC will implement this change.
The GIC administers benefits for employees, retirees, survivors, and dependents of municipal entities that have accepted chapter 32B, § 19 or §23, and have met other transfer requirements of the relevant section (“participating municipalities”). Since chapter 67 of the acts of 2007 rewrote G.L. c. 32B, § 19, the GIC has understood eligibility for health benefits to be generally subject to c. 32A, not chapter 32B, eligibility rules.
Of particular note here are elected officials: per chapter 32A, § 2(b), persons elected by popular vote are eligible for insurance without regard to hours worked. In chapter 32B, §2 (“Employee”), the rule is somewhat different: elected official who work less than half-time may be eligible for health insurance, at local option. Other classes of employees are subject to special rules in chapter 32B that lack any c. 32A counterpart: in c. 32B, certain firefighters and other emergency service workers as well as traffic supervisors are eligible at local option without regard to hours worked. See c. 32B, §§ 2 (“Employee”), 2B, and 3A.
As stated above, to date, the GIC has interpreted G.L. c. 32B, §§ 19 and 23 to permit the GIC to rely on c. 32A eligibility rules to govern eligibility in participating municipalities, even where c. 32A and c. 32B differ from each other. In the regulations finalized on April 12, the GIC is revising that interpretation. Prospectively, the GIC’s interpretation of c. 32B, §§ 19 and 23, is that in the limited circumstances in which c. 32A and c. 32B eligibility requirements vary, c. 32B rules will apply to participating municipalities. See 805 C.M.R. § 8.03(2) and (3). Transitionally, this change creates the challenge of determining how to re-establish local option components of c. 32B.
GIC will presume that present practices reflect local option
In the interests of a smooth transition, by default, the GIC will assume that current practices reflect local option preferences, unless and until the GIC is advised otherwise by the municipality.
Municipalities may exercise local options, with notice to the GIC
Prospectively, municipalities may inform the GIC that they intend to change their local option elections. They must comply with applicable local options laws, where applicable. Additionally, participating municipalities must inform the GIC by May 8, 2013, if they intend to change local option elections for coverage effective July 1, 2013. Prospectively, participating municipalities must notify the GIC three months in advance of the effective date of any change in eligibility related to a change in local option.
Qualifying Status Change Event Documentation
Qualified Status Documentation Chart – Download this document to access a comprehensive overview of qualifying status changes, the allowable changes for that status change, the supporting documentation required, the timeline for submitting the form and documentation for the change, and the effective date of the change.