Today the Department of Health and Human Services (HHS), the Department of Labor (DOL) and the Internal Revenue Service (IRS) released final regulations on short-term, limited duration health insurance (STLDI). The regulations can be found by clicking here.
This rule was issued as a result of the Trump Administration Executive Order 13813 entitled “Promoting Healthcare Choice and Competition Across the United States.” This Executive Order also directed the HHS, DOL and IRS to review previous guidance regarding health reimbursement arrangements (HRAs) and we are still awaiting the agencies response to that directive.
The final regulations essentially follow the rules as proposed in February 2018. Short-term, limited-duration insurance is health coverage provided pursuant to a contract with an issuer that has an expiration date specified in the contract that is less than 12 months after the original effective date of the contract and, taking into account renewals or extensions, has a duration of no longer than 36 months in total. (Prior rules limited short-term, limited duration health insurance to periods of 3 months or less.) Short-term, limited duration insurance does not need to provide all the requirements for health insurance coverage that were added by the Affordable Care Act and the regulations set out notice requirements to inform consumers of that fact.