"[S]ome self-insured plans that offer additional drugs beyond what Medicare Part D requires could potentially be required to comply with health reform. This would only be the case of the Part D benefit was aggregated with or part of the active group health plan. (If it was retiree-only, it would be exempt.) While there is an exception for Medicare supplemental coverage that is insured, no similar exemption exists for self-funded plans. The Departments said they would not take enforcement action against those self-funded plans for non-compliance with health reform, pending further guidance."  MORE >>