On August 7, 2025, the U.S. Departments of Labor, Health and Human Services (HHS), and the Treasury announced they are reconsidering the regulatory definition of short-term, limited-duration insurance (STLDI) through a formal notice-and-comment rulemaking process.
The 2024 final rules amended the definition of STLDI for purposes of its exclusion from the definition of “individual health insurance coverage” under the Public Health Service Act, the Internal Revenue Code, and the Employee Retirement Income Security Act. STLDI is generally exempt from the individual market requirements of the Public Health Service Act and the Affordable Care Act.
Consistent with Executive Order 14219, the departments will review the regulation to determine if amendments are necessary. Until any new rules are finalized, the agencies will not prioritize enforcement actions for violations related to failing to meet the 2024 definition of STLDI, including its notice requirements.
HHS has encouraged states to take a similar enforcement approach. States adopting the federal approach or applying their own definitions of STLDI under state law will not be considered out of compliance with federal enforcement standards during this period.
Stay informed and ahead of the curve — explore more industry insights and program opportunities at ProgramBusiness.com.