August / September 2020 Edition


NADP Submits Comments on IRS Direct Primary Care Agreement Rule

On Aug. 7, NADP filed a comment with the Internal Revenue Service (IRS) on the proposed rule regarding “Certain Medical Care Agreements” (RIN 1545-BP31) that would expand the definition of “medical care” under section 213(d) of the IRS Code, to include health sharing ministries and direct primary care arrangements. This would allow both arrangements to be reimbursable under employee Health Reimbursement Arrangements (HRAs). In the proposed rule, the IRS requested comments on potentially further expanding the definitions in section 213(d) to include “an agreement between a dentist and a patient to provide dental care.”

NADP responded by reiterating the stability and affordability of the dental benefits market and raising concern that of allowing direct dental care agreements to be reimbursable by Health Reimbursement Accounts (HRAs) could lead to a false assumption of comprehensive coverage by enrollees. The comment also reiterated NADP’s principle on policies regarding HRAs:

“Employer provided or financed health benefits coverage of all types is critical to supporting the health and productivity of the workforce. While an array of options for financing coverage can be beneficial to coverage expansion and overall population health, it is important for those options to expand, not erode, coverage.”

Please send any questions on the comment or rule to Government Relations Analyst Owen Urech.



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