What Is A Group Health Plan for Purposes of Adult Dependent Mandate?

[rocknrolls2]

I have looked at the legislative language and the interim final regulations on the requirement to cover adult dependents up to age 26. The term "group health plan" is used but there are many definitions. In other words, is dental coverage subject to the requirement? The interim final regulations do not include a definition nor do they amend an existing regulations to expand the list of sections subject to the definition that has applied for HIPAA and certain other health benefit purposes.

[oriecat]

I was just reading this article http://www.proskauer.com/publications/clie...dren-to-age-26/ and it mentioned "HIPAA excepted stand alone dental and vision plans".

I did a google search on the term "hipaa excepted stand alone dental" and it also found this page http://www.buckconsultants.com/buckconsult...47/Default.aspx which says

Q702. Do these age 26 requirements apply to dental and vision coverage, as well?

A702. No. Stand-alone dental and vision plans (e.g., those with a separate election and costs) qualify as “HIPAA-excepted benefits” and are not subject to this mandate.

I hope that helps.

[CEB]

This is good information, thank you.

[britoski]

This question seems to have come up before. Maybe this will be helpful for those of you who want to pin this down specifically:

PPACA Section 1001 adds an additional section 2714 to the public health services act (PHSA) which provides: "A group health plan ...that provides dependent coverage of children shall continue to make such coverage available for an adult child until the child turns 26 years of age." This provision is added under a new subpart 2 of the PHSA chapter.

PPACA section 1563 makes some conforming amendments to PHSA. Subsection © of the new section 2735 of PHSA (old section 2721) now reads:© Limited, excepted benefits. The requirements of subparts 1 and 2 shall not apply to any individual coverage or any group health plan (and group health insurance coverage offered in connection with a group health plan) in relation to its provision of excepted benefits described in section 300gg-91©(2) of this title if the benefits --(A) are provided under a separate policy, certificate, or contract of insurance; or (B) are otherwise not an integral part of the plan.

PPACA section 1551 provides:" Unless specifically provided for otherwise, the definitions contained in section 2791 of the Public Health Service Act (42 U.S.C. 300gg–91) shall apply with respect to this title."

PHSA 2791 provides the following definition for excepted benefits : "For purposes of this subchapter, the term “excepted benefits” means benefits under one or more (or any combination thereof) of the following... (2) Benefits not subject to requirements if offered separately...(A) Limited scope dental or vision benefits."

So...the adult child coverage extension excludes stand-alone dental/vision. Hope this is helpful!