Reporting Form for Plan Sponsors Offering Limited Wraparound Coverage
CMS has released a form for use by plan sponsors offering limited wraparound coverage to satisfy the reporting required for the coverage to qualify as an excepted benefit. As background, limited wraparound coverage—employer-sponsored coverage intended to supplement (i.e., wrap around) other specified types of coverage—was added as a new type of excepted benefit in 2015 (see our Checkpoint article). Established as a pilot program, limited wraparound coverage can be first offered as an excepted benefit no earlier than January 1, 2016, and no later than December 31, 2018, and must end three years after it was first offered (with a special rule for collectively bargained coverage). In late 2017, CMS issued a notice seeking comments on the possible extension of the pilot program as well as the content of a proposed reporting form (see our Checkpoint article). The form, as finalized, largely mirrors the proposed version.
The form requires the plan sponsor to provide information such as the type of coverage the limited wraparound coverage is designed to supplement (i.e., eligible individual health insurance, a multi-state plan, or basic health program coverage), who is eligible to enroll, and the number of individuals enrolled. The plan sponsor is also required to describe the additional benefits that the limited wraparound coverage is designed to provide (e.g., expanded in-network medical clinics or providers, home health coverage). A glossary is included with definitions of key terms. Plan sponsors must file a form for each type of limited wraparound coverage that they offer. The form must be filed on a one-time basis within the later of 60 days after publication of the form (which was posted on the CMS website on June 25) or 60 days after the first day of the first plan year that the coverage is first offered. The instructions provide an email address where the completed form should be sent.
EBIA Comment: The reporting requirement is intended to help CMS determine whether the exception for limited wraparound coverage is allowing employers to provide employees with benefits comparable to the employer’s group health plan without eroding employer-sponsored coverage. In addition to required reporting, limited wraparound coverage must satisfy strict criteria to be considered an excepted benefit. Eligible plan sponsors offering (or considering offering) limited wraparound coverage should study the reporting form closely so that they are prepared to provide the needed information. For more information, see EBIA’s Health Care Reform manual at Section V.F.6 (“Limited ‘Wraparound’ Coverage”). See also EBIA’s HIPAA Portability, Privacy & Security manual at Section VI.F.6 (“Limited ‘Wraparound’ Coverage”) and EBIA’s Group Health Plan Mandates manual at Section IV.D.6 (“Plans Providing Only Excepted Benefits Need Not Comply With Some Mandates: Limited ‘Wraparound’ Coverage”).
Contributing Editors: EBIA Staff.