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Premium Reimbursement Plans - Still Acceptable?
Guest posted a topic in Health Plans (Including ACA, COBRA, HIPAA)
I'm working to determine whether a company that reimburses its employees up to $5,000 each for the cost of their acquiring health insurance can keep this plan in 2014. Some suggested that this type of arrangement would violate the rules on annual limits (particularly in light of FAQ 11). However, I'm becoming convinced that this type of plan will remain permissible in 2014, given that it is only reimbursing premiums - which do not constitute an essential health benefit. This is based on 29 C.F.R. 2590.715-2711(b)(1), which states: "The rules of this section do not prevent a group health plan, or a health insurance issuer offering group health insurance coverage, from placing annual or lifetime dollar limits with respect to any individual on specific covered benefits that are not essential health benefits to the extent that such limits are otherwise permitted under applicable Federal or State law." I would be interested in getting thoughts from other practitioners. For anyone interested, I noticed this debate was also happening in the comments section of the below article. http://healthaffairs.org/blog/2013/01/25/implementing-health-reform-health-reimbursement-arrangements-and-more/