Commemorating the 10th Anniversary of a Landmark Case

Healthcare has changed dramatically over the past decade. The importance of consumer choice has not.

Ten years after the landmark Central United Life Insurance Co. v. Burwell decision, ManhattanLife proudly commemorates a defining moment for supplemental health coverage and the millions of Americans who value having choices when planning for healthcare expenses.

Amid rising healthcare costs and unprecedented advances in medicine and technology, the principles reinforced by this landmark case remain as relevant today as ever. Preserving access to fixed indemnity insurance, supporting consumer choice, and helping individuals prepare for life's unexpected moments remain essential.

Healthcare coverage often consists of multiple layers working together.

Major medical insurance helps pay for covered healthcare services, but it frequently leaves individuals responsible for deductibles, copayments, coinsurance, transportation expenses and other out-of-pocket costs.

Fixed indemnity insurance is designed to complement major medical coverage by paying predetermined cash benefits for covered medical services or events, regardless of the actual medical expenses incurred. These benefits can provide additional financial flexibility, helping policyholders manage expenses that often accompany illness, injury or hospitalization.

For many individuals and families, fixed indemnity insurance serves as another layer of financial preparedness, offering additional support when unexpected healthcare events occur.

In 2016, ManhattanLife, then operating as Central United Life Insurance Company, successfully challenged a federal regulation that would have imposed requirements on the sale of fixed indemnity insurance that were not authorized by Congress.

The United States Court of Appeals for the District of Columbia Circuit ruled in favor of Central United Life on July 1, 2016. This affirmed that federal agencies cannot expand statutory requirements through regulation beyond what Congress has authorized.

The decision upheld the statutory framework governing fixed indemnity insurance and preserved consumers' access to this important form of supplemental health coverage.

Although the case was decided in a courtroom, its greatest impact has been felt far beyond it.

Ultimately, the decision helped preserve consumers' ability to choose supplemental health coverage that aligns with their unique circumstances and financial goals.

For millions of Americans navigating an increasingly complex healthcare system, maintaining access to these products has continued to provide valuable options for managing healthcare-related expenses.

Preserving Consumer Choice

Every family's healthcare needs are different.

Some individuals prioritize lower monthly premiums and prepare for larger deductibles. Others seek additional financial protection through supplemental insurance that helps address out-of-pocket costs associated with covered medical events.

The demand for policies has also remained steady, as LIMRA data and industry average Hospital Indemnity premiums seem to indicate. It is estimated that 15 to 20 million Hospital Indemnity policies have been sold nationwide since the Central United Life decision.¹

The court's decision reinforced the statutory framework established by Congress, helping preserve consumers' ability to make those choices for themselves.

Rather than limiting available options through expanded regulatory interpretation, the ruling affirmed that those policy decisions remain with Congress.

For consumers, that meant continued access to products designed to complement their existing healthcare coverage.

Supporting Financial Preparedness

Unexpected medical events often bring more than medical bills.

Transportation expenses, lodging, childcare, household obligations, lost income and everyday living costs can quickly become additional financial burdens during recovery.

Fixed indemnity insurance helps provide predictable cash benefits that policyholders can use where they need them most.

That flexibility continues to make supplemental health coverage an important component of many families' financial planning.

A decade after the decision, its impact remains clear. By affirming the statutory requirements governing fixed indemnity insurance, the ruling provided lasting legal certainty for consumers, insurers, employers and insurance professionals while helping preserve access to supplemental health coverage.

Although the healthcare landscape has evolved considerably since 2016, with mounting costs, increasing financial responsibility for consumers and continued advances in medicine and technology, the demand for flexible supplemental coverage has remained constant. The decision continues to support consumer choice, provide regulatory transparency and help ensure individuals and families have access to insurance solutions that prepare them for life's unexpected moments.

2016

• Healthcare deductibles continued to rise.
• Consumers assumed greater responsibility for healthcare costs.
• Supplemental insurance became an increasingly important financial planning tool.
• Central United Life Insurance Co. v. Burwell reinforced the legal framework governing fixed indemnity insurance.

• Healthcare costs remain a leading financial concern for American families.
• Out-of-pocket expenses continue to challenge household budgets.
• Supplemental insurance remains an important option for financial preparedness.
• ManhattanLife continues serving individuals, families, employers and producers with innovative supplemental insurance solutions designed to meet evolving needs.

For more than 175 years, ManhattanLife has remained focused on helping people prepare for life's uncertainties.

While healthcare has changed dramatically, our purpose has remained remarkably consistent. We believe individuals deserve meaningful choices.

We believe supplemental insurance plays an important role in helping families prepare for unexpected healthcare expenses.

We also believe financial protection should complement medical protection.

Those beliefs guided Central United Life through the milestone 2016 case and continue to guide the company today.

Since the court decision, Hospital Indemnity insurers have paid approximately $6.5 to $10 billion in benefits to consumers.¹

While serving ManhattanLife customers is our top priority, our commitment involves a vast community of relationships.

Every day, we work alongside insurance professionals, employers, brokers, and benefit advisors who help consumers understand their options and make informed decisions about their healthcare coverage.

Together, these partnerships help deliver meaningful protection to families across the country.

As ManhattanLife looks toward the future, we remain committed to preserving access to meaningful supplemental health solutions, supporting our distribution partners and helping individuals and families navigate an increasingly complex healthcare landscape with confidence.

Ten years after Central United Life Insurance Co. v. Burwell, we continue building on the principles that made the decision so important—consumer choice, financial preparedness, and dependable protection.

For generations, ManhattanLife has earned the trust of individuals, families, employers and insurance professionals by delivering dependable insurance solutions backed by financial strength and a commitment to service.

As we commemorate the 10th anniversary of Central United Life Insurance Co. v. Burwell, we celebrate more than a legal milestone. We celebrate a decade of preserving consumer choice, strengthening partnerships and helping Americans prepare for whatever tomorrow may bring.

¹ LIMRA Workplace Supplemental Health Sales (2024)