Supplemental Health Insurance as Excepted Benefits

[Don Levit]

Folks:

Today's Benefits Link provided Field Assistance Bulletin 2007-04.

This answers a lot of concerns we had several months ago regarding whether certain individual policies would be considered group health plans.

Policies that are "excepted benefits" are not group health plans.

Go to:

http://www.dol.gov/ebsa/pdf/fab2007-4.pdf.

Don Levit

[Oh so SIMPLE]

As I read the FAB, truly 'supplemental' policies are excepted. Individual policies for major medical could yet be part of a group health plan, subject to the health reform requirements for group health plans and that often are not in those individual policies. It depends on the level of involvement of the employer in choosing the individual policies, cutting a premium price break for its employees, or bearing part of the expense of the premiums.

[Don Levit]

Oh so Simple:

I agree with your assessment.

However, I wonder why the employer not bearing part of the premium was not mentioned as one of the criteria for the safe harbor?

Don Levit