On Friday, July 7, the Departments of Labor, Health and Human Services, and Treasury (the Agencies) issued a Proposed Rule that would reform the rules governing when fixed indemnity plans and short term limited duration insurance can be treated as “excepted benefits.” The Proposed Rule also poses a series of questions on level funded plan arrangements that indicate that the Agencies are concerned with the potential hidden liabilities that these plans may pose for their small employer sponsors.
Read the full analysis from Steptoe & Johnson
The Council is evaluating whether to submit comments and we encourage members to advise on any issues or concerns with the Proposed Rule that we should consider in our assessment. Comments are due on September 11, 2023. Please reach out to Katie King, VP of Health Policy & Strategy, with feedback.