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  • Do Dental and Vision Plans Have to Cover Dependents to Age 26?

    According to the Department of Health and Human Services (HHS)  the Department’s position that if benefits are “excepted  benefits” under HIPAA, the PPACA’s group health plan mandates and insurance  market reform requirements (e.g., no lifetime dollar limits on essential  health benefits, only “restricted” annual dollar limits on essential health benefits prior to 2014, no annual dollar limits on essential health benefits in 2014 and beyond, extended plan eligibility for adult children up to age 26, no waiting periods in excess of 90 days [effective 2014], insured health plan nondiscrimination rules, new internal claims and appeals/external review  processes) do not apply. 
    A dental or vision benefit plan is a HIPAA-excepted benefit if it is:

     *Provided under a separate policy, certificate or contract of insurance (for insured plans)

     * Is otherwise not an integral part of the health care plan.
     For dental or vision benefits to be considered not an integral part of the plan (whether insured or self-insured), participants must have a right not to  receive the coverage and, if they do elect to receive the coverage, must pay
    an additional premium  Accordingly, if a plan provides its dental or vision benefits pursuant to a
    separate election by a participant and the plan charges even a nominal employee contribution toward the coverage, the dental or vision benefits would constitute excepted benefits, and the PPACA group health plan mandates and insurance market reform provisions would not apply to that coverage.

    To put this in “plain english”  If the dental and vision plans are provided by a separate carrier than the medical and if an employee can make a separate election and premium payment for the dental and vision without having to have these benefits mirror the medical,  then the carrier does not have to offer dependent benefits to age 26.  Many dental and vison carriers are offering to continue benefits to age 26 as a courtesy, please check with the carrier to determine their position.

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