The Departments of Labor (“DOL”), Health and Human Services (“HHS”), and the Treasury (collectively, the “Departments”) have become aware of health insurance carriers selling supplemental products that provide a single benefit. At least one carrier is characterizing this type of coverage as an excepted benefit. These carriers claim that

the products meet the criteria for supplemental coverage to qualify as an excepted benefit outlined in the Departments’ guidance and are designed to fill in the gaps of primary coverage in the sense that they are providing a benefit that is not covered under the primary group health plan. The Departments issued an FAQ that provides guidance on whether health insurance coverage that supplements group health coverage by providing additional categories of benefits can be characterized as supplemental excepted benefits.

Click the link to download the bulletin for more information: Guidance Issued Regarding Supplemental Excepted Benefits – 031815R