What plans are exempt from the HIPAA portability requirements and the new annual and lifetime maximums?
A517. HIPAA portability requirements have both statutory and regulatory exemptions that now will apply to the new annual and lifetime maximums. These rules exempt: • Retiree only plans (separate legal plan from actives) • Stand-alone dental or vision plans • Medicare Supplements (but as currently defined, Medicare coordinated plans offered by employers are not exempt) • Flexible Spending Accounts, which as defined includes reimbursement accounts that apply to retirees that are limited to $500 per year. • Worker’s compensation benefits • Medical benefits provided under automobile insurance or general liability insuranceWe hope that regulations will expand the scope of these exemptions at least from some of the new requirements. In particular, the entire regulatory scheme of HIPAA and the new rules are meant to provide broad based coverage to individuals not yet on Medicare, so we would hope and strongly suggest that the Medicare supplement exemption be expanded to include any medical be
