Dive Brief:
- The final rule released this week on wraparound benefit coverage continues to mandate that health plan payers can only provide excepted benefits as a supplement to primary coverage—not as a substitute.
- The finalized document remains similar to that which was proposed in December 2014.
- The rule creates a new category of excepted benefits, and clarifies that employers can offer their part-time and retired employees coverage that wraps around and increases any benefits they receive through primary "qualifying individual coverage," as well as supplement any marketplace coverage that they provide to full-time employees through the Multi-State Plan program.
Dive Insight:
Excepted benefits are generally limited or somehow tangential/supplemental to medical care, such as workers' compensation, dental and vision coverage, disease-specific coverage, Medicare supplement policies, etc.
The wraparound coverage program, which has garnered some controversy, is being offered only as a pilot program at this time. The rules specify that wraparound coverage can be offered as excepted benefits if it is first offered no earlier than January 1, 2016 and no later than December 31, 2018, and that it can not extend beyond either three years after it is first offered, or the end of the last collective bargaining agreement relating to the plan.
The program has been delayed a year from the dates provided in the proposed rule.