We care about Aflac’s policyholders affected by the recent wildfires:
To help provide relief for Utah policyholders residing in Utah who were affected by the wildfires, Aflac will provide a premium grace period starting July 31, 2025, and ending Sept. 29, 2025. This grace period also provides an extension of filing deadlines for claims and leniency for any other action required under the policy. Aflac will provide a replacement copy of the policy upon request by the policyholder.
For Network Dental and Vision Members:
This grace period also provides an extension of filing deadlines for claims; relaxation of prior authorization, precertification, and referral requirements; access to appropriate out-of-network providers due to unavailability on in-network providers or the members’ displacement; and leniency for any other action required under the certificate. A replacement copy of the certificate will be provided upon request by the certificate holder. Affected members should contact Aflac Benefit Solutions (formerly Argus Dental and Vision) at 855-819-1873, Option 1, for assistance.
We care about Aflac’s policyholders affected by the recent weather:
To help provide relief for California policyholders residing in Humboldt, Mendocino, Modoc, Napa, Shasta, Sonoma, and Trinity Counties affected by the winter storms, Aflac will provide a premium grace period starting Jan. 31, 2025, and ending Sept. 29, 2025. This grace period also provides an extension of filing deadlines for claims and leniency for any other action required under the policy. Aflac will provide a replacement copy of the policy upon request by the policyholder.
For Network Dental and Vision Members:
This grace period also provides an extension of filing deadlines for claims; relaxation of prior authorization, precertification, and referral requirements; access to appropriate out-of-network providers due to unavailability on in-network providers or the members’ displacement; and leniency for any other action required under the certificate. A replacement copy of the certificate will be provided upon request by the certificate holder. Affected members should contact Aflac Benefit Solutions (formerly Argus Dental and Vision) at 855-819-1873, Option 1, for assistance.
We care about Aflac’s policyholders affected by the recent wildfires:
To help provide relief for Oregon policyholders residing in Oregon who were affected by the wildfires, Aflac will provide a premium grace period starting July 16, 2025, and ending Sept. 15, 2025. This grace period also provides an extension of filing deadlines for claims and leniency for any other action required under the policy. Aflac will provide a replacement copy of the policy upon request by the policyholder.
For Network Dental and Vision Members:
This grace period also provides an extension of filing deadlines for claims; relaxation of prior authorization, precertification, and referral requirements; access to appropriate out-of-network providers due to unavailability on in-network providers or the members’ displacement; and leniency for any other action required under the certificate. A replacement copy of the certificate will be provided upon request by the certificate holder. Affected members should contact Aflac Benefit Solutions (formerly Argus Dental and Vision) at 855-819-1873, Option 1, for assistance.
We care about Aflac’s policyholders affected by the recent wildfires:
To help provide relief for Oregon policyholders residing in Crook County who were affected by the wildfires, Aflac will provide a premium grace period starting July 12, 2025, and ending Sept. 10, 2025. This grace period also provides an extension of filing deadlines for claims and leniency for any other action required under the policy. Aflac will provide a replacement copy of the policy upon request by the policyholder.
For Network Dental and Vision Members:
This grace period also provides an extension of filing deadlines for claims; relaxation of prior authorization, precertification, and referral requirements; access to appropriate out-of-network providers due to unavailability on in-network providers or the members’ displacement; and leniency for any other action required under the certificate. A replacement copy of the certificate will be provided upon request by the certificate holder. Affected members should contact Aflac Benefit Solutions (formerly Argus Dental and Vision) at 855-819-1873, Option 1, for assistance.
We care about Aflac’s policyholders affected by the recent flooding:
To help provide relief for Texas policyholders and/or certificate holders residing in Bandera, Bexar, Burnet, Caldwell, Coke, Comal, Concho, Gillespie, Guadalupe, Kendall, Kerr, Kimble, Llano, Mason, McCulloch, Menard, Reeves, San Saba, Tom Green, Travis, and Williamson counties who were affected by the flooding, Aflac will provide an extended premium grace period starting July 2, 2025, and ending Sept. 8, 2025. This grace period also includes an extension of filing deadlines for claims and leniency for any other actions required under the policy and/or certificate. Aflac will provide a replacement copy of the policy and/or certificate upon request by the policyholder and/or certificate holder.
For Network Dental and Vision Members:
This grace period also includes an extension of filing deadlines for claims; temporary relaxation of prior authorization, precertification, and referral requirements; access to appropriate out-of-network providers due to unavailability of in-network providers or member displacement; and leniency for any other actions required under the certificate.
Affected members should contact Aflac Benefits Solutions (formerly Argus Dental and Vision) at 855-819-1873, option 1, for assistance.
We care about Aflac’s policyholders affected by the recent wildfires:
To help provide relief for Oregon policyholders residing in Klamath County who were affected by the wildfires, Aflac will provide a premium grace period starting July 8, 2025, and ending Sept. 08, 2025. This grace period also provides an extension of filing deadlines for claims and leniency for any other action required under the policy. Aflac will provide a replacement copy of the policy upon request by the policyholder.
For Network Dental and Vision Members:
This grace period also provides an extension of filing deadlines for claims; relaxation of prior authorization, precertification, and referral requirements; access to appropriate out-of-network providers due to unavailability on in-network providers or the members’ displacement; and leniency for any other action required under the certificate. A replacement copy of the certificate will be provided upon request by the certificate holder. Affected members should contact Aflac Benefit Solutions (formerly Argus Dental and Vision) at 855-819-1873, Option 1, for assistance.
We care about Aflac’s policyholders affected by the recent wildfires:
To help provide relief for Oregon policyholders residing in Umatilla County who were affected by the wildfires, Aflac will provide a premium grace period starting July 2, 2025, and ending Sept. 02, 2025. This grace period also provides an extension of filing deadlines for claims and leniency for any other action required under the policy. Aflac will provide a replacement copy of the policy upon request by the policyholder.
For Network Dental and Vision Members:
This grace period also provides an extension of filing deadlines for claims; relaxation of prior authorization, precertification, and referral requirements; access to appropriate out-of-network providers due to unavailability on in-network providers or the members’ displacement; and leniency for any other action required under the certificate. A replacement copy of the certificate will be provided upon request by the certificate holder. Affected members should contact Aflac Benefit Solutions (formerly Argus Dental and Vision) at 855-819-1873, Option 1, for assistance.
We care about Aflac’s policyholders affected by the recent wildfires:
To provide relief for New Mexico policyholiders and/or certificate holders residing in Grant County and affected by the Trout Fire, Aflac will provide the following protections for policyholders and/or certificate holders: Provide an extended premium grace period from Thursday, Jun. 12, 2025 through Monday, Sep. 15, 2025. Offer policyholders and/or certificate holders a payment plan of no less than six (6) months if unable to pay the delinquency after the extended day grace period (This applies to all coverages except life.). Work with policyholders and/or certificate holders on premium payments to prevent lapse and cancellation of policies. Waive late fees and penalties. Waive early refill time limits on active prescriptions. Allow additional time for actions required under the policy and/or certificate and the submission of documents due to limited access to service and mobility. Provide an extension of filing deadlines for claims and leniency for any other action required under the policy and/or certificate. Provide a copy of the policy and/or certificate to the policyholder and/or certificate holder upon request.
In addition to the above, Aflac through Aflac Benefits Solutions will provide the following protections for Network Dental and Vision members and providers: Waive cost sharing and deductibles. Permit one eyeglass or contact lens replacement and one hearing aid replacement during the pendency of the Emergency Order, waiving frequency limitations. Permit one replacement for dentures or other prosthodontic devices during the pendency of this Emergency Order, waiving frequency limits. Waive additional fees, charges, referrals, eligibility and prior authorization requirements for medically necessary services, whether emergent or not. This applies to benefits and services obtained from both in- and out-of-network providers. Extend medical providers' reporting requirements for claims submissions and for additional information relating to claims. Fully reimburse out-of-network providers at the usual, customary, and reasonable rate.
Affected members should contact Aflac Dental and Vision (formerly Argus Dental and Vision) at 855-819-1873, option 1, for assistance.
We care about Aflac’s policyholders affected by the recent weather:
To help provide relief for California policyholders residing in Trinity County affected by the Dec. 15, 2024, and Dec. 29, 2024, winter storms, Aflac will provide billing leniency for impacted insureds, an extension of filing deadlines for claims and leniency for any other action required under the policy. Aflac will provide a replacement copy of the policy upon request by the policyholder. Affected members should contact Aflac at 800-992-3522 for assistance.
For Network Dental and Vision Members:
This also provides an extension of filing deadlines for claims and leniency for any other action required under the certificate. Affected members are not required to obtain prior approval when accessing appropriate out-of-network providers when in-network providers are unavailable. The cost-sharing for out-of-network will be in amount equal to cost-sharing affected members would have paid for the provision of that service in-network. A replacement copy of the certificate will be provided upon request by the certificate holder. Affected members should contact Aflac Benefit Solutions (formerly Argus Dental and Vision) at 855-819-1873, Option 1, for assistance.
We care about Aflac’s policyholders affected by the recent levee failure:
To help provide relief for California policyholders residing in San Joaquin County affected by the Oct. 21, 2024, Victoria Island Levee failure, Aflac will provide billing leniency for impacted insureds, an extension of filing deadlines for claims and leniency for any other action required under the policy. Aflac will provide a replacement copy of the policy upon request by the policyholder. Affected members should contact Aflac at 800-992-3522 for assistance.
For Network Dental and Vision Members:
This also provides an extension of filing deadlines for claims and leniency for any other action required under the certificate. Affected members are not required to obtain prior approval when accessing appropriate out-of-network providers when in-network providers are unavailable. The cost-sharing for out-of-network will be in amount equal to cost-sharing affected members would have paid for the provision of that service in-network. A replacement copy of the certificate will be provided upon request by the certificate holder. Affected members should contact Aflac Benefit Solutions (formerly Argus Dental and Vision) at 855-819-1873, Option 1, for assistance.
We care about Aflac’s policyholders affected by the recent wildfires:
To help provide relief for California policyholders residing in Los Angeles and Ventura Counties affected by the wildfires, Aflac will provide billing leniency for impacted insureds, an extension of filing deadlines for claims and leniency for any other action required under the policy. Aflac will provide a replacement copy of the policy upon request by the policyholder. Affected members should contact Aflac at 800-992-3522 for assistance.
For Network Dental and Vision Members:
This also provides an extension of filing deadlines for claims and leniency for any other action required under the certificate. Affected members are not required to obtain prior approval when accessing appropriate out-of-network providers when in-network providers are unavailable. The cost-sharing for out-of-network will be in amount equal to cost-sharing affected members would have paid for the provision of that service in-network. A replacement copy of the certificate will be provided upon request by the certificate holder. Affected members should contact Aflac Benefit Solutions (formerly Argus Dental and Vision) at 855-819-1873, Option 1, for assistance.
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By: John Hickman and Carolyn Smith, Alston & Bird LLP
The IRS has released a helpful memorandum that lays to rest some recent confusion relating to the taxation of benefits received from fully insured health indemnity products when the premium is paid on a pretax basis. The recent IRS memo confirms the long-standing position (based on regulations and rulings dating back to the 1960s) that such benefits are includible in the employee’s income only to the extent that the amounts received exceed the individual’s unreimbursed medical expenses. This article discusses the tax issues and the IRS memos and is relevant to employers of all sizes.
Fixed-indemnity insurance as discussed in this article pays a fixed-dollar amount as set forth in the policy based on a medical event trigger, such as a visit to the doctor, a hospital stay, or the diagnosis of a particular condition or disease (such as cancer). Although the trigger for payment is based on a medical event, the amount of the payment is not related to the amount of any medical expense incurred as a result of the payment trigger, and benefits are not coordinated with other health coverage that the individual may have.
For decades, the issue of how these types of fixed-indemnity benefits are taxed has been settled based on the statutory provisions, regulations and IRS rulings.
The IRS looked at several situations in which health indemnity benefits exceeded the amount of medical expenses incurred in a 1969 ruling (Rev. Rul. 69-154). As with insured health indemnity benefits today, the health indemnity policies included in the ruling did not coordinate with other coverage or otherwise reduce benefits because the medical expense had been fully reimbursed. The IRS concluded that the health indemnity coverage in the ruling would provide tax-free benefits to the extent of any unreimbursed medical expenses.
In a memorandum released in December 2016, the IRS addressed an abusive tax arrangement marketed primarily to small employers that utilized a so-called “wellness program” coupled with a self-funded indemnity plan that purported to provide significant tax benefits for both employers and employees. Under the program, disproportionally large benefits – which often corresponded to the amount of wages sought to be sheltered from tax – could be triggered by nontraditional medical events. Whereas most health indemnity policies are fully insured and triggered solely by an accident or sickness as required under the tax laws, benefits under the self-funded health indemnity plan lacked economic substance in that payments could be made for merely completing a health risk assessment or calling a health coach.
While there are many legitimate wellness programs, the IRS had little trouble in revealing the fatal tax defects of the arrangement under review. Unfortunately, in discrediting the abusive arrangement, the IRS used overly broad language which could be read to indicate that benefits under any fixed indemnity health plan would always be fully taxable. This reading is inconsistent with the regulations and the earlier controlling Revenue Ruling. Thus, our belief was that this statement was limited to the abusive tax arrangements and could not as a matter of law impact taxation of traditional, fully insured fixed-indemnity benefits. Nevertheless, the IRS memo generated some confusion.
In a recent memorandum dated April 24, 2017,1 the IRS made it clear that nothing had changed with respect to traditional fully insured fixed-indemnity arrangements. In particular, the April 2017 memo states that the prior memo was “intended to address situations in which no medical expenses were incurred or reimbursed, and should not be read to modify the analysis or result in Rev. Rul. 69-154.”
The recent memo also includes a helpful example of a traditional fixed-indemnity health plan that pays fixed amounts on the occurrence of health events such as a medical office visit or a hospital stay where the premiums for the policy are paid on a pretax basis through a cafeteria plan. The plan pays $200 for a medical office visit. If the covered individual’s unreimbursed medical costs as a result of the visit were $30, then $30 would be excluded from the employee’s income and the excess amount of $170 would be taxable.
The IRS has now reconfirmed the income tax treatment of benefits paid under fully insured fixed indemnity plans. If the premium is paid by the employer or by the employee through a cafeteria plan, the benefits are subject to income tax only to the extent that the employee’s unreimbursed medical expenses are less than the benefit payment.
This article is provided for informational purposes only and is not intended as legal advice by Aflac or Alston & Bird LLP.
This material is intended to provide general information about an evolving topic and does not constitute legal, tax or accounting advice regarding any specific situation. Aflac cannot anticipate all the facts that a particular employer or individual will have to consider in their benefits decision-making process. We strongly encourage readers to discuss their HCR situations with their advisors to determine the actions they need to take or to visit healthcare.gov (which may also be contacted at 1-800-318-2596) for additional information.
Aflac herein means American Family Life Assurance Company of Columbus and American Family Life Assurance Company of New York.
