AIM Guaranteed Issue

[myinsurebiz]

There are many holes in the referenced statutes.

When speaking of 1191b - Nick left out a few captioned words:

" Such term does not include coverage consisting solely of coverage of excepted benefits (as defined in section 1191b (c) of this title). "

Consisting "solely" of . . .

With GTL and AMLI underwriting the AIM product to the extent of providing certain "benefits" via a "group health plan" - then this would qualify the AIM plan as creditable coverage based on :

(c) (1) (A)

and

(c) (1) (B)

since certain components of the AIM plan is part of a "group plan" provided by those insurance carriers. In addition - if the AIM plan didn't have "health insurance" components - then why the necessity of having to be a licensed health insurance agent to market it?

So far - based on the statutes posted by Nick - there isn't sufficient evidence that the AIM plan wouldn't provide "creditable coverage" and thus be HIPPA compliant.

Just a note - I contacted a head guy at AMLI and asked him to explain why the AIM plan was creditable coverage and HIPPA compliant. He said:

" When any part of a Form Filing with a State's DOI has certain group health plan components - such as the AIM plan - where it isn't strictly an Indemnity product and the plan pays "medical expenses incurred up to ( key phrase - "up to" ) a certain determined fee or level " - then that excludes the plan as being an "exception" according to subsection 1191b.

So - since the group plan provides coverage for "expenses incurred" in various components - i.e. physicians visits, surgical procedures, PPO Network Repricing, etc and that the form filing is that of a "association group insurance plan" that can only be sold to members of the specific association - it is in fact insurance AND creditable coverage.

They even had this affirmed in several meetings with attorneys representing ERISA.

Called GTL and received basically the same answer.

Since the certificate of creditable coverage will be issued by the insurance carrier - i.e. - GTL or AMLI and not from the marketing company AIM - my opinion, which is also confirmed by the insurance carrier, is that AIM product would be considered creditable coverage.

Tom

 

[somarco]

Just a few questions, Tom . . .

When & where did you get your law degree?

Remind me again. Just how much experience (you can use months rather than years since it produces a bigger number) do you have in the health insurance business? Specifically, how much experience in HIPAA rules & regs?

As for contacting the carriers, when you talked to GTL did they confirm, preferably in writing, that they are indeed the issuing carrier for the entire product in certain states? Or did they simply say they insure the accident portion only?

Has anyone connected with AIM, GTL or AMLI provided letters from the various DOI's that prove the product is filed, and approved, in the states where it is offered?

In case you haven't figured it out, I am trying to be civil about this since you are clearly in over your head. You should limit your conversation, at least on this forum, to talking about folks that earn a six figure income in the first three months they use your system. It is so much more credible than defending this AIM product.

 

[myinsurebiz]

Just a few questions, Tom . . .

When & where did you get your law degree?

LOL - who needs a law degree when the statutes explain themselves and are validated by someone within the actual insurance carrier that underwrites the product in question.

As for contacting the carriers, when you talked to GTL did they confirm, preferably in writing, that they are indeed the issuing carrier for the entire product in certain states? Or did they simply say they insure the accident portion only?

I didn't ask them those questions. I asked them if they deemed the AIM product as being "creditable coverage" and as being HIPPA compliant.

Has anyone connected with AIM, GTL or AMLI provided letters from the various DOI's that prove the product is filed, and approved, in the states where it is offered?

Bob - when you sell a new Golden Rule product - do you ask the carrier to provide the same? Doubtful.

The gentleman with AMLI acknowledged that AMLI has filed all necessary forms in the State's in which their products are used.

In case you haven't figured it out, I am trying to be civil about this since you are clearly in over your head.

Well actually Bob - unlike most here - I go straight to the horses mouth when i need an interpretation or an explanation. Once again - an old hen assuming that insurance is rocket science - when in fact - if one were to just ask the right people, instead of "assuming" what the U S Code says or may say - well . . .

You should limit your conversation, at least on this forum, to talking about folks that earn a six figure income in the first three months they use your system.

I've never stated the above Bob. You see - you are a shining example of - no offense - of someone spouting off at the mouth without facts or "credible" evidence. Show me where i made the above statement or promise Bob?

I know you old hens have a problem with someone jumping into "your" sand pile and being able to do what most old hens believe takes a hundred years of "studying" and "training" to accomplish. But - I'm ok with that because I see the fruits of my labor everyday.

In serious tone - the reason I investigated the AIM product is while doing some live transfers on Health last week - a few callers couldn't qualify for traditional health insurance. So - in order to provide a service to those clients - I sought out a solution. There are others - HomeLand, AccessPlansUSA, etc - but AIM actually has the best value in a GI health / indemnity product. So - before I sell something I check it out real good. AIM passed the test and my calls to the carriers solidified my assessment of the product.

Should you not like it - that's your perogative. When speaking to a few issuing health carriers today to see if they would accept a certficate of coverage from AMLI - they not only said they would - but have!

Any hoo - off to a ball game . . .

Tom

 

[somarco]

Word of advice.

Stick to peddling crap insurance and creating 90 day wonders. You are way out of your league on this one.

 

[myinsurebiz]

Bob,

I spoke with Vice Presidents of the two main carriers - GTL and AMLI - I would imagine that they know well enough if THEIR product is Creditable Coverage.

LOL @ crap insurance. Man - I sell Baltimore Life, ForeThought, UHL, Golden Rule, Assurant, Anico, IAC, etc - they don't seem to be "crap" to me Bobby . . .

But - I enjoyed the game and had to check back in the zoo to see what's up . . .

Tom

 

[Todd King]

There are many holes in the referenced statutes.

When speaking of 1191b - Nick left out a few captioned words:

" Such term does not include coverage consisting solely of coverage of excepted benefits (as defined in section 1191b (c) of this title). "

Consisting "solely" of . . .

With GTL and AMLI underwriting the AIM product to the extent of providing certain "benefits" via a "group health plan" - then this would qualify the AIM plan as creditable coverage based on :

(c) (1) (A)

and

(c) (1) (B)

since certain components of the AIM plan is part of a "group plan" provided by those insurance carriers. In addition - if the AIM plan didn't have "health insurance" components - then why the necessity of having to be a licensed health insurance agent to market it?

Tom

I'm going to play devil's advocate here and ask exactly how this qualifies as a "group plan"?

§ 300gg–91. Definitions


(a) Group health plan (1) Definition The term "group health plan" means an employee welfare benefit plan (as defined in section 3(1) of the Employee Retirement Income Security Act of 1974 [29 U.S.C. 1002 (1)]) to the extent that the plan provides medical care (as defined in paragraph (2)) and including items and services paid for as medical care) to employees or their dependents (as defined under the terms of the plan) directly or through insurance, reimbursement, or otherwise.


I'm just asking....

 

[moonlightandmargaritas]

It's interesting to note that other limited, defined benefit indemnity mini-meds point out that they're not HIPAA compliant.

 

[myinsurebiz]

Below is an excerpt from the email I received from a Vice President from one of the carriers.

4) In recognizing 10 types of creditable coverage the first defined by HIPPA (a group health plan) is sweeping. In defining exceptions to creditable coverage, the definition is very narrow and requires that Indemnity plans are excepted only when "… coverage consisting solely of excepted benefits…" are in place. Since "our" surgical and accident benefits are "expenses incurred" the benefit plans are not eligible to be excepted. This is consistent with HIPPA's intent to broadly protect consumers against unfair pre-existing condition limitations.

Hope that helps.

I did extensive research on this matter yesterday, made my due diligence phone calls and got my information DIRECTLY from the source. I have faith in their abilities to not only know what the heck their product is - but also their position on the "creditable coverage" issue.

Of course - my views are only my opinion and my interpretation of what "I" believe - to each to their own I always say . . .

Good luck.

Tom

p.s. - Todd, I interpret a group isn't necessarily "employee" based - an association and their members can also be a "group" - look at all the association health plans out there - based on "group".

Association clients are typically issued a insurance certificate versus a policy - since they all are covered under one master policy or plan.

 

[moonlightandmargaritas]

I interpret a group isn't necessarily "employee" based

While that may be the true, in this case the definition is not ambiguous.

It clearly refers to employees (and their dependents) as below, specifically.

Group health plan [/b] (1) Definition The term "group health plan" means an employee welfare benefit plan (as defined in section 3(1) of the Employee Retirement Income Security Act of 1974 [29 U.S.C. 1002 (1)]) to the extent that the plan provides medical care (as defined in paragraph (2)) and including items and services paid for as medical care) to employees or their dependents

 

[somarco]

GTL & AMLI are not exactly experienced major med carriers, so I doubt either one of them would know creditable coverage if it bit them on the butt.

So AIM is supposed to be a group plan, huh? And that makes it creditable, huh? Guess no one ever heard of group mini-med plans . . . which are NOT creditable.

Don't believe me? Just ask some of the carriers that write group mini-med plans.

AIM is not an employer/employee plan. At best, it is a MEWA.

Anyone been following the MEWA issues of the last few years? Outside of Taft-Hartley plans, almost every group MEWA has been shut down, usually by the AG. Most MEWA's, especially self funded ones, are beyond the jurisdiction of the DOI, so the AG has to get involved.

Even still, an insured group plan must be filed with each state where they will offer the coverage. Last time I checked, this plan was not on record with the GA DOI.

Not on file as individual coverage. Not on file as an insured group plan.

So what's left?

FWIW, I just emailed this link to one of the honcho's at the GA DOI. I asked if the plan is approved for sale in Georgia. He is usually pretty good about getting back to me. Sure you won't mind.