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Earlier today, the Self-Insurance Institute of America, Inc. (SIIA) submitted formal comments to several questions pertaining to stop-loss insurance and level-funded arrangements as set forth in a recent Federal Notice of Proposed Rulemaking (NPRM). Within the NPRM, the Federal Departments included a number of questions geared toward better understanding level-funded arrangements. As part of these efforts, the Departments asked various questions relating to stop-loss insurance, ranging from the development of attachment points and compliance with Federal group health plan requirements to actual plan costs and refunds paid to level-funded plan sponsors. The full proposed NPRM can be found here.
SIIA’s comments provide an industry-wide perspective on the background, purpose, and use of stop-loss insurance as a financial backstop on behalf of self-insured plan sponsors. Most importantly, SIIA’s comments focus on the fact that stop-loss insurance is not health insurance, and thus, regulations applicable to group health plans and other health insurance products are inapplicable to stop-loss. SIIA also outlines the calculation and usage of both aggregate and specific attachment points, and the role the stop-loss insurance carrier plays when insuring a self-insured plan sponsor from potential catastrophic plan liabilities.
As Federal and State regulators continue to review stop-loss insurance and level-funded
arrangements, SIIA will maintain its leading voice in educating, clarifying, and defending the use
of stop-loss.
If you have questions or would like to talk further, please contact Ryan Work (rwork@siia.org) or Chris Condeluci (ccondeluci@siia.org).
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