The Affordable Care Act (ACA) and Prevention of Significant Deterioration (PSD)

As a company that specializes in navigating clients through complex air quality permitting – specifically PSD and Non-attainment New Source Review (NNSR), ALL4 is familiar with challenging regulations that don’t always make sense.  Understanding the regulations (and many changes), the interpretations and policy memos, and the techniques to minimize the impact of PSD and NNSR on our clients has been the cornerstone of ALL4 since our inception.

As I review health insurance plans and the Affordable Care Act (ACA) and the impact on ALL4 in 2014 and beyond, I find myself analyzing the plans and taking the same systematic approach that we do with PSD and NNSR projects.  Over the years our “PSD-type approach” to healthcare has led us to: (1) migrating from one top-rated carrier to another, (2) switching from a preferred provider organization (PPO) model to a high deductible (HD) plan and health savings account (HSA) model, and (3) implementing a HD plan and health reimbursement arrangement (HRA) model. Heck, the health insurance arena and PSD are so similar that they both even have more acronyms than you can remember!!

At ALL4, we strive to be “best in class” and we are extremely proud of the fact that we provide high-end health insurance to our employees and pay 100% of the premiums for both individuals and families.  In our current model, we pay not only 100% of the premiums, but also 100% of the applicable deductibles!  We believe strongly that we have the top consultants in our business and that we need to compensate them accordingly to be able to continue to provide the level of service to our clients that that they have come to expect.  Even though our benefits advisors tell us that we are insane, we have been fortunate to continue to provide this type of benefit by tackling health insurance the same way that we tackle PSD. 

However, I am starting to feel like we are bumping up against a PSD or NNSR significant threshold level when it comes to managing costs for health insurance.  Under the ACA, our small business of 39 is looking at a 54.6% increase in insurance premiums in 2014 – over $110K per year!  After I heard this news and picked myself up off the ground, we started looking at it again using our PSD-type approach and it looks like we can implement another “PSD-avoidance” technique and renew under our current plan in December 2013 to push off the impact of the ACA until December 2014.  We can do this for an increase of (only) 14.4%.  Over the next 12 months, we will continue to tackle healthcare the same way that we help our clients tackle PSD projects at their facilities… we will track the regulatory process, we will look for creative options to minimize the impact on our operations, and we will implement a plan in December 2014 that provides best in class benefits while controlling costs.  I understand our clients’ frustration with PSD and NNSR now more than ever!