afa59010_ered_Life__Among_Other_Changes__Comments
[Benefit Type] Employee Assistance Program [Does Reinsurance Fee Apply?] Usually not. The Reinsurance Fee does not apply if the program does not provide "major medical coverage." [Comments] 
Note that this test is different from other tests (such as the patient-centered outcomes research trust institute fee ("PCORI Fee") regulations, which focus on whether the EAP provides "significant benefits in the nature of medical care or treatment"). A separate Quarles & Brady alert on the PCORI fee is found here.
Employers, Insurers Face New “Reinsurance” Fee of $63 Per Covered Life, Among Other Changes
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