New Mexico and Stop Loss insurance

What do you guys think of this?



http://ift.tt/1vwJNFf



Some insight into their thinking might be found here: http://ift.tt/18iD4EY



Although some of the comments in the letter on having a maximum attachment point would indicate they might not exactly understand the product...(or maybe I don't understand their argument.)



So the actuary highlights this in the definition of "health insurance" to make the argument in the letter: "insurance that reimburses or pays on behalf of an employer or health care plan sponsor all or part of the employer's, sponsor's or health care plan's expenses or obligations arising pursuant to a health care plan"



The only way I can see the argument is if they parse the language to get it to read: "insurance that reimburses...an employer...all or part of the employer's...expenses or obligations arising pursuant to a health care plan". That doesn't seem like the right way to interpret that law...I can't think of anyone else that has claimed stop loss is truly a health coverage?

New Mexico and Stop Loss insurance