non calendar year prescription drug plans and Rev Proc 2004-22 grandfathering

[jstorch]

Per Rev. Proc. 2004-22, prescription drug plans are "grandfathered" so they can be offered w/HSA plans through 2005.

How are insurers handling non-calendar-year prescription drug plans that would run 2005-2006 & HSAs?

Only thoughts I have are

1. make short plan years terminating on 12/31/05.

2. not offer them at all after the plan year ending in 2005.

3. let them be and tell those taking it that they won't be HSA eligible as of 1/1/06.

Anyone know what insurers are doing in practice or have other ideas?