AHIP, together with ACLI, and on behalf of their member LTC insurers, submitted a comment letter to the Federal Interagency Task Force on Long-Term Care Insurance’s (Task Force) in response to their invitation for comments on potential reforms to federal laws, regulations, and policies that complement reforms at the state level relating to the regulation of long-term care insurance (LTCI). In its letter, AHIP commended the Task Force for considering the challenges of long-term care (LTC) financing that American consumers face as a matter of national interest, requiring a coordinated response from the federal government.
The Task Force has been reviewing various proposals to reform federal laws and regulations concerning LTCI, including, among other options, the federal policy options presented by the NAIC to Congress for its consideration in April 2017. Having reviewed the NAIC options, AHIP offered recommendations that are achievable and would meaningfully improve consumers’ access to private LTCI coverage. AHIP recommendations specifically outline potential reforms to federal laws, regulations, and policies that would complement regulatory reforms at the state level related to LTCI. Consistent with AHIP’s LTC federal legislative advocacy proposals, AHIP called for the Task Force’s consideration of the following achievable changes described below:
- Launch a national educational campaign to help consumers understand both the need for and benefits of LTC coverage.
- Provide tax incentives to expand consumer access to LTC coverage through workplace and retirement plan options:
- Making LTC coverage available through Internal Revenue Code (IRC) Section 125 cafeteria plans and Flexible Spending Arrangements (FSA);
- Allowing tax-free premium payments for LTCI policies either from or within their 401(k)s, 403(b)s, IRAs, and other retirement plans; and
- Permitting employees to make additional contributions to their Health Savings Accounts (HSA) to pay for LTCI premiums.