Late last Friday, the Dept. of Health & Human Services (HHS), the Dept. of Labor (DOL) and the Internal Revenue Service (IRS) issued proposed rules amending the excepted benefits* regulations.
The statutes establish four categories of excepted benefits…
1) Non-health: automobile insurance, liability insurance, workers compensation, and accidental death/dismemberment coverage;
2) Limited Scope: vision, dental, long-term care and certain health FSAs;**
3) Non-coordinated: specified diseases/illnesses coverage (such as cancer policies) and hospital indemnity insurance; and
4) Supplemental: Medicare, the Civilian Health & Medical Program or Tricare.
The guidance released last week appears to impact the second category of excepted benefits highlighted above (limited scope). TASC Governmental Affairs is currently in the process of reviewing this new information in order to assess the effect – if any – on our products and services. We will communicate further on this topic in the near future.
* Excepted benefits are generally exempt from the healthcare reform requirements added by HIPAA and PPACA.
** These benefits must either be provided under a separate policy, certificate, contract, etc. or otherwise not be an integral part of a group health plan, whether insured or self-insured.
