afa59010_ered_Life__Among_Other_Changes__Comments
[Benefit Type] Dental Plan [Does Reinsurance Fee Apply?] Usually not. Many dental plans are "excepted benefits" under HIPAA. If so, the Reinsurance Fee does not apply. In addition, the preamble to the regulations states that "stand-alone dental coverage" is not subject to the fee. It is not clear if this provides an additional exception for employers whose dental plan is not an "excepted benefit." [Comments] 
Excepted benefit test: If there is a separate fully insured contract for the plan, then it is an excepted benefit. For self-funded plans, the plan must meet two tests to be an excepted benefit. The participant: (1) must be able to elect the benefit separately; and (2) if elected, must pay an additional premium for the coverage. Thus, self-funded, 100 percent employer-paid dental plans do not qualify as an "excepted benefit," and the Reinsurance Fee will apply to such plans. In both situations, coverage must be limited to treatment of the mouth.
Employers, Insurers Face New “Reinsurance” Fee of $63 Per Covered Life, Among Other Changes
Comments