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Although this exception does not appear in the Administrative Simplification provisions of HIPAA , it was asserted that it is guidance with respect to the treatment of long term care insurance as a limited benefit coverage and not as coverage that is so `` sufficiently comprehensive '' that it is to be treated in the same manner as a typical , comprehensive major medical health plan arrangement . Caroline M. Hoxby , a professor at the Harvard University Department of Economics , wrote in a research paper that a good accountability plan " includes a combination of testing , standards against which the test results can be compared , and report cards that relay this information ( as well as information on schools ' level and use of resources ) to parents and policy-makers . It was suggested that HHS clarify whether the definition of health plan , particularly the `` group health plan '' and `` health insurance issuer '' components , includes a disability plan or disability insurer . The commenter presumed that the we had intended to exclude from the definition of `` health plan '' ( and from coverage under the proposed rule ) all ERISA plans that are small ( less than 50 participants ) or are administered by a third party , whether large or small , based on the statement at 64 FR 60014 , note 18 . The Beijing municipal government is still working on its housing plan , but rental increases and an affordable price tag on existing apartments are likely to figure prominently . It should be noted that Delphi Corp. owes its pension plan a $ 400 million payment in January , according to the Pension Benefit Guaranty Corp ., which also opposes the big bonus plan for the company 's top executives . In addition , it is becoming increasingly important for governments to consider development issues as they prepare and execute their long-term capital plans . Therefore , to the extent that a certain benefits plan or program otherwise meets the definition of `` health plan '' and is not explicitly excepted , that program or plan is considered a `` health plan '' under paragraph ( 1 ) ( xvii ) of the final rule . In such a case , specific requirements apply to the group health plan .