Archived Insight | June 4, 2015

Final Rule on Limited Wraparound Coverage Under the ACA

The final rule on wraparound coverage under the Affordable Care Act issued by the Departments of Treasury, Labor, and Health and Human Services (collectively, the "Departments" responsible for implementing the law) allows plan sponsors to provide limited benefits that supplement (or "wrap around") coverage obtained through certain individual health insurance policies. The final rule describes two kinds of limited wraparound benefits: those available only to part-time employees or pre-Medicare eligible retirees enrolled in individual health insurance policies (such as a plan available through a Marketplace) and those that can be used to supplement multi-state plans offered through the public Marketplace. Such limited "wraparound" benefits are considered "excepted benefits," which means they are not be subject to the Affordable Care Act’s group health plan mandates, such as the prohibition on annual dollar limits.

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This page is for informational purposes only and does not constitute legal, tax or investment advice. You are encouraged to discuss the issues raised here with your legal, tax and other advisors before determining how the issues apply to your specific situations.

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