Tag: Health Insurance

Affordable Care Act: Will Your Group Health Plan be “Affordable” in 2022?

By Anita Byer, Setnor Byer Insurance & Risk

The IRS announced that the Affordable Care Act’s affordability threshold for employer-sponsored group health plans will be 9.61 percent in 2022. Employers with 50 or more full-time or full-time equivalent employees (Applicable Large Employers or ALEs) must recognize that next year’s affordability threshold will be lower than the 9.83 percent used in 2021. This means that a group health plan that was affordable in 2021 may be considered unaffordable in 2022, despite being exactly the same. As a result, many ALEs will need to make adjustments to avoid potential ACA penalties in 2022.

ALEs are generally required to offer full-time employees “affordable” minimum essential health care coverage to avoid the ACA’s employer shared responsibility (pay-or-play) penalty. Affordability is calculated as a percentage of household income. Since employers typically do not know their employees’ household income, ALEs can use one of the ACA’s affordability safe harbors to determine the most employees can be required to pay without exceeding the affordability threshold.

For example, let’s assume Sam worked 40 hours per week for 52 weeks in 2022. If Sam earned $10 per hour, the most Sam can be required to pay for the lowest-cost, self-only coverage option offered by Sam’s employer is:

  • $166.57 per month (W-2 Safe Harbor Method);
  • $124.93 per month (Rate of Pay Safe Harbor Method); or
  • $103.15 per month (Federal Poverty Line Safe Harbor Method—2021).

If Sam earned $15 per hour, Sam’s required contribution for the lowest-cost, self-only coverage option cannot exceed:

  • $249.86 per month (W-2 Safe Harbor Method);
  • $187.39 per month (Rate of Pay Safe Harbor Method); or
  • $103.15 per month (Federal Poverty Line Safe Harbor Method—2021).

The affordability threshold for group health plans beginning in 2022 is only a fraction of a percent lower than this year’s threshold, but the consequences for ALE’s that fail to adapt accordingly can be substantial. To ensure compliance with the ACA’s affordability requirement in 2022, ALEs need to evaluate and possibly adjust their health plan pricing options, cost-sharing structure, and in some cases, compensation levels.

Please contact us if you would like to learn more about ACA-compliant group health plan options for 2022.

Affordable Care Act: Will Your Group Health Plan be Affordable in 2019?

Unlike the Individual Mandate, the Affordable Care Act’s Employer Mandate isn’t going anywhere in 2019. Employers with 50 or more full-time and full-time equivalent employees will still have to offer “affordable” health coverage to avoid ACA penalties. But, there is a sliver of good news. Next year, employers will be able to increase the required employee contribution for coverage under their group health plans.

To satisfy the ACA’s initial affordability requirement, an employee’s required contribution for the lowest cost, self-only coverage could not be more than 9.5 percent of the employee’s household income. However, the initial affordability percentage is adjusted annually by the Internal Revenue Service. In 2019, the affordability percentage will be 9.86 percent.

When compared to prior years, the 2019 affordability adjustment represents the largest percentage increase under the ACA.

2014    9.5

2015    9.56

2016    9.66

2017    9.69

2018    9.56

2019    9.86

We can use the ACA’s affordability safe harbors to translate this percentage increase into dollars and cents. These safe harbors provide various methods for calculating the most an employer can charge employees for the lowest cost, self-only health coverage option without exceeding the ACA’s affordability threshold.

  • W-2 Safe Harbor. The maximum monthly contribution for a federal minimum wage employee ($7.25 per hour) who works 40 hours per week for 52 weeks in 2019 will be $123.91 (+ $3.77).
  • Rate of Pay Safe Harbor. The maximum monthly contribution for a federal minimum wage employee ($7.25 per hour) in 2019 will be $92.93 (+ $2.83).
  • Federal Poverty Line Safe Harbor. Based on the 2018 single individual FPL of $12,140, the maximum monthly contribution in 2019 will be $99.75 (+ $3.03).

These increases may be modest, but they can add up quickly for very large employers. They can also provide some much-needed wiggle room for employers teetering on the edge of unaffordability. The ultimate impact of the 2019 affordability percentage increase can be inconsequential or substantial. Employers will need to reevaluate their cost-sharing structure to find out.

Please contact us if you would like to learn more about ACA-compliant group health plans.

Gender Identity and Sex Stereotyping Under the Affordable Care Act

Did you know that the Affordable Care Act (ACA) contains a civil rights provision? The ACA prohibits discrimination on the basis of race, color, national origin, sex, age or disability in certain health programs and activities. Despite becoming law in 2010, final implementation rules were not issued by the Department of Health and Human Services (HHS) until May 2016. On July 18, 2016, the Nondiscrimination in Health Programs and Activities final rule went into effect.

Under the ACA, individuals cannot be excluded from participation in, be denied the benefits of, or otherwise be subjected to discrimination under any covered health program or activity on the basis of race, color, national origin, sex, age or disability. Though the final rule generally incorporates existing federal nondiscrimination laws and policies , provisions dealing with sex discrimination, primarily gender identity and sex stereotyping, are getting the most attention.

The final rule states that sex discrimination includes discrimination based on sex, pregnancy, childbirth and related medical conditions. Individuals cannot be denied health care based on their sex and women and men must be treated equally in terms of health care and insurance coverage. However, the final rule also prohibits discrimination on the basis of gender identity and sex stereotyping.

Gender identity is an individual’s internal sense of gender. It may be male, female, neither, or a combination of both. An individual’s gender identity may be different from the sex they were assigned at birth. A transgender individual is an individual whose gender identity is different from the sex assigned to that person at birth.

Sex stereotypes are stereotypical notions of masculinity or femininity. They include expectations of how individuals represent or communicate their gender to others and that individuals will consistently identify with and conform to stereotypes associated with their assigned gender. Sex stereotypes also include gendered expectations related to the appropriate roles of a certain sex.

According to HHS, categorical coverage exclusions or limitations for all health care services related to gender transition are discriminatory. Individuals must be treated in a manner consistent with their gender identity. Providers may not deny or limit treatment that is ordinarily or exclusively available to individuals of one gender because the person seeking treatment identifies as belonging to another gender.

The manner in which the final rule expanded the traditional scope of sex discrimination to include gender identity and sex stereotyping represents a fairly significant policy shift. However, HHS admits that the final rule does not resolve whether discrimination on the basis of an individual’s sexual orientation alone violates the ACA’s nondiscrimination provision. Nevertheless, HHS states that allegations of sexual orientation discrimination will be evaluated by the Office for Civil Rights to determine whether they involve the sorts of stereotyping that violate the ACA’s nondiscrimination provision.

Despite not being directly covered by the ACA’s nondiscrimination rules, many employers will be affected indirectly. Employers providing fully insured group health plans may be affected because their insurance companies are covered by the rule. Employers using a covered third-party administrator to manage their self-fund group plan may also be affected by the rule. Consequently, employers should have at least a basic understanding of the ACA’s nondiscrimination rules.

At Setnor Byer Insurance & Risk, we are committed to guiding you through the constantly changing health care landscape and offer a number of valuable risk management solutions to help you properly and efficiently manage your employee benefits, group health and business insurance programs.

Please contact us if you would like more information about complying with the Affordable Care Act or subscribe to our weekly risk mangement newsletter.

Is Telemedicine Right for Your Business?

Industry experts estimate that 80% of employers will offer telemedicine by 2018. So what exactly is this trending health care benefit? Well, telemedicine generally refers to the practice of using telecommunications technologies (phone, Internet, etc.) to diagnose and treat patients, and in case you haven’t noticed, it’s come a long way.

If you ask a Group Benefits Manager at Setnor Byer Insurance & Risk you’ll discover:

  • The Centers for Medicare & Medicaid Services describes telemedicine as a cost-effective alternative to providing medical care.
  • The American Medical Association says telemedicine is a key innovation that can maintain patient safety, improve access to health care and control costs.
  • Industry analysts expect significant growth in the telemedicine market over the next few years.

You’ll also learn that employers are increasingly relying on telemedicine. According to a recent survey, a third of U.S. employers currently offer telemedicine services to employees as a low-cost alternative to doctor office visits for non-serious medical issues. In 2014, only 22% offered telemedicine services.

A primary benefit of telemedicine is fewer unscheduled absences by employees needing to see or take their child to a doctor for non-serious medical issues. Research shows that a majority of doctor visits are unnecessary. A cough, for example, can often be treated safely and effectively with telemedicine. (According to the Centers for Disease Control and Prevention, the most frequent reason for going to the doctor is, ahem…a cough.)

Employers offering telemedicine services also benefit from:

  • Healthier employees
  • Fewer employee sick days
  • Increased productivity
  • Measureable reduction in health care (insurance) costs

Telemedicine service plans are typically structured as discount card programs. These plans are not insurance and should not be considered a substitute for health insurance. Employers considering a telemedicine program should work with a reputable broker to not only find the right plan, but to also avoid those trying to take advantage of a rapidly growing market.

At Setnor Byer Insurance & Risk, we can help you:

  • Evaluate options
  • Find the best solution
  • Obtain competitive pricing
  • Implement and integrate a new plan into existing benefit programs

If you would like more information, please contact a Group Benefits Manager at Setnor Byer Insurance & Risk.

For more information about group health and other benefits, you can subscribe to our weekly risk management newsletter.

Is Your Group Health Plan Considered ‘Affordable’ under the ACA?

Applicable Large Employers (ALEs) are generally employers that average at least 50 full-time and full-time equivalent employees. Under the Affordable Care Act, ALEs can either provide health insurance coverage to employees or pay a penalty. To avoid a penalty, ALEs must offer health coverage to at least 95% (70% in 2015) of its full-time employees and their dependents. But, not any old group health insurance coverage will do.

Coverage that is offered must provide minimum value and must be affordable. The minimum value requirement is generally met if the plan covers at least 60% of the costs of benefits. To be affordable, the employee’s share of the premium cannot be more than 9.5% of that employee’s annual household income.

Since employers generally will not know each full-time employee’s household income, employers may use one or more of the ACA’s three affordability safe harbors. If an employer satisfies one or more of these safe harbors, coverage will be considered affordable even if it costs more than 9.5% of a particular employee’s annual household income.

Form W-2. Coverage will generally be considered affordable if the employee’s required calendar year contribution for the employer’s lowest cost self-only coverage does not exceed 9.5 percent of that employee’s Form W-2 wages.

  • Calculated on an employee-by-employee basis at the end of the calendar year.
  • Employee’s required contribution amount or percentage must be consistent throughout the calendar year, so discretionary adjustments to employee contribution requirements for a pay period are not allowed.
  • Wages are adjusted if coverage is not offered for an entire calendar year.
  • Generally produces the highest ‘affordable’ monthly contribution because the calculation is based on wages for all hours worked and paid time off wages (sick, vacation, etc.).
  • Optimal for employers with a relatively stable workforce that are unlikely to reduce compensation levels during the year.

 

Rate of Pay. Coverage will generally be considered affordable if the employee’s required monthly contribution for the lowest cost self-only coverage does not exceed 9.5% of an amount equal to 130 multiplied by the employee’s lowest hourly rate of pay during the calendar month or the hourly rate on the first day of the coverage period (generally the first day of the plan year), whichever is lower. Monthly salaries are used for non-hourly employees.

  • Calculated monthly on an employee-by-employee basis.
  • Employees credited with 130 hours of work per month, regardless of hours actually worked.
  • Generally produces a lower ‘affordable’ monthly contribution than the Form W-2 safe harbor because the calculation is based on wages for 130 hours of work per month (30 hours per week).
  • The maximum monthly ‘affordable’ contribution for an employee making the federal minimum wage of $7.25 per hour is $89.54 ($7.25 x 130 = $942.50 x .095 = $89.54). The monthly maximum would be $123.50 for an employee making $10 per hour and $148.20 for an employee making $12 per hour.

 

Federal Poverty Line. Coverage will generally be considered affordable if the employee’s required monthly contribution for the lowest cost self-only coverage does not exceed 9.5% of the applicable calendar year’s federal poverty line (FPL) for a single individual, divided by 12.

  • The 48 contiguous states are given a single FPL; Alaska and Hawaii each have their own FPL.
  • The 2015 FPL for the 48 contiguous states is $11,770, so the maximum monthly ‘affordable’ contribution would be $93.18.
  • Generally produces the lowest ‘affordable’ monthly contribution of all the safe harbors.

 

These safe harbors are optional. ALEs may use one or more of these safe harbors and can apply them to any reasonable category of employees, but they must be applied uniformly and consistently to all employees in a category. Reasonable categories can be based on specified job categories, compensation type (hourly or salary), geographic location or other similar bona fide business criteria.

At Setnor Byer Insurance & Risk, we are committed to guiding you through the constantly changing health care landscape. In addition to our other valuable risk management solutions, Setnor Byer Insurance & Risk has an online tool to help clients complete their ACA information reports.

Please contact us if you have any questions or would like to discuss how we can help you comply with health care reform.

Is Telemedicine Right For You?

Telemedicine generally refers to the practice of using telecommunications technologies (phone, Internet, etc.) to diagnose and treat patients, and in case you haven’t noticed, it’s come a long way. Consider this:

  • The Centers for Medicare & Medicaid Services describes telemedicine as a cost-effective alternative to providing medical care.
  • The American Medical Association says telemedicine is a key innovation that can maintain patient safety, improve access to health care and control costs.
  • Industry analysts expect significant growth in the telemedicine market over the next few years.

Employers are taking notice of the benefits of telemedicine. According to a recent survey, 22% of large U.S. employers currently offer telemedicine services to employees as a low-cost alternative to doctor office visits for non-serious medical issues; 37% expect to begin doing so in 2015.

A primary benefit of telemedicine is fewer unscheduled absences by employees needing to see or take their child to a doctor for non-serious medical issues. Research shows that a majority of doctor visits are unnecessary. A cough, for example, can often be treated safely and effectively with telemedicine. (According to the Centers for Disease Control and Prevention, the most frequent reason for going to the doctor is…a cough.)

Employers offering telemedicine services also benefit from:

  • Healthier employees
  • Fewer employee sick days
  • Increased productivity
  • Measureable reduction in health care (insurance) costs

Telemedicine service plans are typically structured as discount card programs. These plans are not insurance and should not be considered a substitute for health insurance. Employers considering a telemedicine program should work with a reputable broker to find the right plan and avoid those trying to take advantage of a rapidly growing market.

At Setnor Byer Insurance & Risk, we make it easy to:

  • Evaluate options
  • Find the best solution
  • Obtain competitive pricing
  • Implement and integrate a new plan into existing benefit programs

If you would like more information, please contact us.

Small Group Health Premiums under the Affordable Care Act

Controlling health insurance premiums was a primary goal of health care reform. Before the Affordable Care Act (ACA), small group health insurers could vary premiums for a number of reasons, such as a group’s overall health status, size, age, gender, history or industry. As a result, some small groups had significantly higher premiums than others. Small groups could even face large premium increases based on a new diagnosis for a single employee.

For small group health insurers, these discriminatory premium variations are no longer allowed. Under the ACA, small group health insurers can only consider four factors when varying premium rates.

Individual vs. Family Coverage: Small group health insurers are allowed to vary rates based on who is enrolled in the plan. Different rates can be charged depending on whether the plan covers only an individual or a family.

Rating Area: Rating areas allow insurers to charge more in areas where medical costs are higher. Under the ACA, each state is authorized to establish their own rating areas; otherwise, federally-established default rating areas will be used.

A state’s rating areas must be based on the following geographic boundaries: counties, three-digit zip codes, or metropolitan and non-metropolitan statistical areas. The Centers for Medicare & Medicaid Services may evaluate rating areas to confirm whether they are actuarially justified, not unfairly discriminatory, reflect significant differences in health care costs, lead to stability in rates over time, and apply uniformly to all issuers in a market.

Age: Small group health insurers are allowed to vary premium rates based on age. However, variations cannot exceed a 3:1 ratio for those 21 and older. In other words, premiums for the highest price age groups cannot be more than three times the lowest price age groups.

The ratio is calculated using three uniform age bands:

  • Child (0-20): A single age band with the same actuarially justified premium rate based on a standard population.
  • Adult (21-63): One-year age bands with increasing rates based on an age-rating curve.
  • Older Adult (64+): A single age band with the same premium rate.

Tobacco Use: Small group health insurers can also vary premium rates for tobacco users, though variations cannot exceed a 1.5:1 ratio. (Premiums for tobacco users cannot be more than 1.5 times higher than for non-users.) The regulations define tobacco use as using tobacco an average of four or more times per week within the past 6 months, excluding religious or ceremonial usage, and includes all tobacco products.

At Setnor Byer Insurance & Risk, we are committed to guiding you through the ever-changing health care landscape. Check back with us periodically for informational updates about the Affordable Care Act. In the meantime, if you have specific questions, contact us.

Learn more about our Affordable Care Act Program.

If you would like to subscribe to our newsletters please click here.

Supreme Court to Rule on Fate of the Affordable Care Act…Again

Once again, the fate of the Affordable Care Act (ACA) rests with the United States Supreme Court. Though the constitutionality of the ACA isn’t being challenged in King v. Burwell, the stakes may be just as high. This case involves the interpretation and applicability of the ACA’s individual health insurance subsidies (tax credits and cost-sharing reductions), and the outcome will likely depend on how the Court interprets four simple words.

The ACA created new marketplaces (Exchanges) where individuals can purchase health insurance. Only 16 states and the District of Columbia elected to establish their own state-based marketplaces. The federal government set up federally facilitated marketplaces in the remaining 34 states. This is important because the ACA provides that subsidies are available to individuals covered by a health plan enrolled in “through an Exchange established by the State.”

According to the King plaintiffs, this provision of the ACA clearly says (and means) that individuals purchasing health insurance in one of the 34 states with federally facilitated marketplaces are not entitled to subsidies. The Internal Revenue Service, on the other hand, has a broader interpretation of this provision. According to IRS regulations, subsidies are available to anyone who is enrolled in a health plan through an Exchange, regardless of whether it is state-based or federally facilitated.

The question before the Supreme Court is, simply stated, whether the IRS has the authority to extend ACA subsidies to health coverage purchased through federally facilitated marketplaces. Those who think this is an easy question should know that two federal appellate courts, the Fourth Circuit and the D.C. Circuit, had different answers.

What would happen if the Court rules against the IRS and holds that subsidies are not available to individuals in those 34 states with federally facilitated marketplace? Though difficult to predict, some believe such a result could prove catastrophic for the ACA.

According to a study by the RAND Corporation, individual health insurance enrollment in the 34 states with federally facilitated marketplaces would decline by 9.6 million to 4.1 million, a 70% decrease. The study also found that decreased enrollment would increase premiums. The average premium for a 40-year-old nonsmoker purchasing a silver plan in these states would go up $1,610, a 47% increase.

If the Court strikes down the IRS regulations, the Urban Institute estimates that the number of uninsured in 34 states would increase by 8.2 million people (a 44% increase relative to the number uninsured under the ACA as currently implemented). It would also eliminate $28.8 billion in tax credits and cost-sharing reductions in 2016 ($340 billion over 10 years) for 9.3 million people.

According to the Kaiser Family Foundation, disallowing subsidies in states with federally facilitated marketplaces may destabilize the individual insurance market in every state. It could also impact the ACA’s employer mandate applicable to large employers, since the penalty is triggered when an employee receives a subsidy.

At this point no one knows if or how King will affect health care reform. Could it undermine the ACA? Will it send shockwaves through the health insurance industry nationwide? We’ll just have to wait and see.

At Setnor Byer Insurance & Risk, we are committed to guiding you through the ever-changing health care landscape. Check back with us periodically for informational updates about the Affordable Care Act. In the meantime, if you have specific questions, contact us.

If you’d like to subscribe to our weekly newsletters please click here.

Are You Ready for the New Affordable Care Act Reporting Requirements?

The Affordable Care Act (ACA) requires Applicable Large Employers (ALEs) with 50 or more full-time or full-time equivalent employees to file information returns with the Internal Revenue Service and provide statements to their full-time employees about employer-offered health insurance coverage. This information will be used to administer the ACA’s employer shared responsibility provisions (employer mandate) and to determine whether an employee is eligible for the premium tax credit.

Filing Forms (Drafts)

In 2014, the IRS released non-final draft versions of two forms that ALEs can use to satisfy these reporting requirements.

  • Form 1095-C (Employer-Provided Health Insurance Offer and Coverage)
  • Form 1094-C (Transmittal of Employer-Provided Health Insurance Offer and Coverage Information Returns)

Filing Deadlines

ALEs must file these forms with the IRS on or before February 28 (March 31 if filed electronically) of the year immediately following the calendar year for which the offer of coverage information is reported. For calendar year 2014, there is no filing requirement. For calendar year 2015, these forms must be filed by February 29, 2016 (or March 31, 2016 if filed electronically).

ALEs must also furnish a Form 1095-C to each full-time employee by January 31 of the following year. The first Forms 1095-C are due to these individuals by February 1, 2016.

Form 1095-C

ALEs must file a Form 1095-C (or a substitute form) for each employee who was a full-time employee for any month of the calendar year. This form is used to report specific health insurance coverage information for each full-time employee to the IRS, such as:

  • which months the employee was a full-time employee
  • any offers of health coverage that meet the minimum value standard made to the employee and family members each month
  • the employee’s share of the monthly premium for the lowest-cost insurance that offers minimum value health coverage
  • whether any safe harbors are applicable to the employee
  • whether the employee was enrolled in the plan

Form 1094-C

ALEs must use Form 1094-C to transmit its Forms 1095-C to the IRS. A Form 1094-C must be attached to any Forms 1095-C filed by an ALE. One transmittal form can be used to cover all Forms 1095-C filed by an ALE or multiple transmittal forms can be used. The information reported with this form includes:

  • the total number of Forms 1095-C submitted with this particular transmittal
  • the total number of Forms 1095-C that will be filed by the ALE
  • whether the ALE is a member of an aggregate group (multiple employers treated as a single employer)
  • whether special rules or transition relief apply to the ALE

Though these ACA reporting forms are not due until 2016, large employers cannot wait until the last minute. Given the technical nature and complexity of the new ACA reporting requirements, legal and tax professionals should be consulted when preparing any forms filed with the IRS.

At Setnor Byer Insurance & Risk, we are committed to guiding you through the health care reform process. Check back with us periodically for future informational updates about the Affordable Care Act. If you have specific questions about the Act or if you are ready to take action and would like to see how Setnor Byer Insurance & Risk can help, contact us.

If you’d like to subscribe to our weekly newsletters please click here.

Understanding Excepted Benefits Under the Affordable Care Act

Many employers offer benefits packages that provide employees with more than just health insurance coverage. Though some of these benefits, like pre-paid legal service plans, are clearly not health-related, others may provide employees with some health-related benefits. Does this mean they are subject to the Affordable Care Act’s health insurance market reforms? Not necessarily.

Certain types of benefits, due to their nature, are not subject to a number of health-related laws, including the Affordable Care Act, the Health Insurance Portability and Accountability Act, the Mental Health Parity Act and the Genetic Information Nondiscrimination Act. These are known as excepted benefits.

There are four categories of excepted benefits.

  1.         Benefits Excepted In All Circumstances

The following benefits, or any combination thereof, are considered excepted benefits in all circumstances:

  • Coverage only for accident (including accidental death and dismemberment)
  • Disability income coverage
  • Liability insurance, including general liability and automobile insurance
  • Coverage issued as a supplement to liability insurance
  • Workers’ compensation or similar coverage
  • Automobile medical payment insurance
  • Credit-only insurance (for example, mortgage insurance)
  • Coverage for on-site medical clinics
  1.         Limited Excepted Benefits

A number of benefits may be considered excepted benefits if they are provided under a separate policy, certificate or contract of insurance. They can also qualify as a limited excepted benefit if they are not an integral part of a group health plan, which means that participants may decline coverage or that claims for benefits are administered under a separate contract than claims for any other benefits under the plan.

One or more of the following benefits may qualify as a limited excepted benefit:

  • Limited-scope dental benefits
  • Limited-scope vision benefits
  • Long-term care benefits
  • Health flexible spending arrangements
  • Employee assistance programs (EAPs)
  1.         Noncoordinated Excepted Benefits

Coverage for only a specified disease or illness, such as a cancer-only policy, may qualify as a noncoordinated excepted benefit. Hospital indemnity or other fixed indemnity insurance may also qualify if it pays a fixed dollar amount per day (or per other period) of hospitalization or illness regardless of the amount of expenses incurred.

To qualify as a noncoordinated excepted benefit:

  • Benefits must be provided under a separate policy, certificate or contract of insurance;
  • There is no coordination between the benefits provided and an exclusion of benefits under any group health plan maintained by the same employer; and
  • Benefits are paid regardless of whether benefits are provided under any group health plan maintained by the same employer.
  1.         Supplemental Excepted Benefits

The following benefits may qualify as supplemental excepted benefits if they are provided under a separate policy, certificate or contract of insurance:

  • Medicare supplemental health insurance (Medigap or MedSupp insurance);
  • Coverage supplemental to the managed health care program established by the Department of Defense (TRICARE); and
  • Similar supplemental coverage specifically designed to fill gaps in primary coverage, such as coinsurance or deductibles, but which does not include coverage that becomes secondary or supplemental only under a coordination-of-benefits provision.

Excepted benefits must satisfy a number of specific requirements set forth in the federal regulations. Employers should consult a knowledgeable and licensed professional before taking action or making changes to their benefits packages.

If you would like more information about excepted benefits or would like to see how Setnor Byer Insurance & Risk can help with your employee benefits package, contact us.

If you’d like to subscribe to our weekly newsletters please click here.