MIB Comments on the Cancellation of the Association Healthcare Plan

Dear Members of MIB:

As an initial matter, Laura and I here at the Montana Independent Bankers (MIB) wish you a merry Christmas 2013 and Happy New Year 2014.  We trust this has been a happy and safe holiday season for you and yours.

Second, I write to inform  about the unexpected cancellation of our Association health care plan, and to express our disappointment regarding the same.

In 2011, in response to suggestions made by the membership of the MIB to sponsor a health care plan, the Association worked with Payne Financial Group, now PayneWest Insurance, to create and offer a healthcare plan to our member banks and associate members.  The plan, which went into effect in 2012, proved to be a valued member benefit to MIB’s members and associate members.

In 2013, building on the value provided to our membership by the MIB sponsored health plan, the Association paid for a wellness program for the participants in the MIB health plan.  The MIB was pleased to offer this benefit, and had plans to continue to expand the Association plan.

Unfortunately, as you are aware by now, the MIB sponsored association health care plan is no more.  As best as the Association can understand, a determination was made by the Montana State Auditor’s Office on or around December 4, 2013 that, while our health care plan was Affordable Care Act (ACA) compliant in terms of the scope of coverage, the Association itself is no longer qualified, under the terms of the ACA, to be a healthcare plan sponsor.  In sum, the Auditor’s office determined that, under federal regulatory guidelines, the Association cannot serve, apparently, as the umbrella sponsor for a small group health plan.

It goes without saying that neither the Association staff nor any member of the MIB Board had any advanced notice that this outcome was even a possibility prior to the time we were made aware of the ruling that discontinued the MIB-sponsored plan.   Indeed, as you will see from page 12 of the most recent edition of our magazine, the Community Banker, our health care plan representative Lori Fearon submitted an article stating that the MIB plan met or exceeded all ACA-imposed health care plan mandates.  In addition, the MIB Board was assured by PayneWest on at least two occasions in 2013 that the MIB-sponsored plan passed ACA muster and would continue after January 1, 2014.  Alas, that is not the case, and had we been given advanced of notice of this cancellation we certainly would have passed that fact on to you.

The Association is aware that representatives from PayneWest have been in touch with every bank and associate member that was a participant in our healthcare plan to find them a substitute health plan.  The Association is also aware of the burden that the State Auditor’s decision to discontinue the MIB sponsored plan has imposed upon each of you personally, upon your staff, and upon your institutions.  This burden is only compounded by the fact that the denial decision came at the 11th hour and was made right before the start of the holiday season.  Obviously, this is a less than ideal situation, and one for which the MIB is truly sorry.   The fact that this decision to discontinue the MIB plan was made without our consent, without our even being consulted, and without our prior knowledge makes the cancellation decision only more difficult to swallow.

While the Association is no longer qualified to serve as a health plan sponsor, this does not mean that the Association will no longer attempt to provide a health care benefit to you and your staff.  As noted above, earlier this year, the MIB Board voted to provide a wellness benefit to our plan members.   The Association understands that this wellness plan is being incorporated into your “new” health care plans.  We trust you will continue to find this program beneficial.  In addition, prior to this setback, the Association Board was exploring other options to provide additional health-related benefits to our members and associate members in the years to come.  The Board will continue to review those additional coverage options.

What is more, the Association recently started the Community Banker Compliance (CBC) Program.  The CBC Program is designed both for your bank’s compliance officer as well as for other staff members who have the responsibility of enforcing such regulations.  This program provides multi-level compliance training and support through live workshops, webinars, newsletters, and online forums.  Montana Independent Bankers is pleased to sponsor and to cover a large portion of the cost of the CBC Program so that your bank can receive the lowest registration rates in the nation.  We know this continues to be a difficult time for community banks, and we want to do our utmost as an association to support you.

The Association is truly disappointed that government regulators unilaterally determined that we are not qualified to sponsor our own health care plan despite the Association’s desire to continue doing so.  However, as it has done since 1968, the Association will continue to move forward, will continue to do its best to provide the highest services to our valued members, and will continue to advocate for policies that reduce your regulatory burden.  In the meantime, if there is anything we here at the Association or the MIB Board can do to assist you during this difficult transition time, or if you have any questions about the regulators’ decision, please do not hesitate to call me at (406) 449-7444 or email me.

Sincerely,

James E. Brown
Executive Director 

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