Short-Term, Limited-Duration Insurance (April 23, 2018)

Health Care

The Church Alliance submitted a comment in response to the proposed rule (the “Proposed Rule”) regarding short-term, limited-duration insurance (“STLDI”), issued jointly by the Department of the Treasury, the Department of Labor, and the Department of Health and Human Services (together, the “Departments”). The Church Alliance expressed concern that the Proposed Rule could create an uneven regulatory environment, which could challenge the financial solvency for programs such as the Church Alliance member health plans. To prevent this result, the Church Alliance comment requested that STLDI be limited to filling short-term coverage gaps, and that the Departments refrain from lengthening the maximum period of STLDI beyond six months.