Court Finds Health Reimbursement Benefits Not Covered by PSEBA
In a recent decision, the Illinois Appellate Court upheld a fire protection district's (District) denial of certain supplemental benefits to a disabled firefighter who was receiving benefits under the Public Safety Employee Benefits Act (PSEBA). Carter v. Fox Lake Fire Protection District.
A firefighter was injured in the line of duty and applied for and received a duty disability pension. The firefighter was also eligible for, and received, benefits under PSEBA, which provides health insurance benefits to public safety officers who suffer a catastrophic injury in the line of duty. For six years, the District provided the disabled firefighter with the PSEBA health benefits, and also covered the firefighter under the District's vision, dental, and life insurance plans as well as the District's health reimbursement benefits that provided reimbursement for certain deductibles. In 2023, however, the District notified the firefighter that PSEBA does not include the vision, dental, and life insurance benefits or the health reimbursement benefits and stopped coverage for those benefits. The firefighter sued, and the circuit court ruled in favor of the District. The firefighter appealed the denial of the health reimbursement benefits to the Appellate Court (he did not challenge the denial of vision, dental, and life insurance benefits).
The Appellate Court examined the language of PSEBA and determined that the statute was clear that PSEBA benefits cover the premium for the health insurance plan, but expressly excludes "supplemental benefits that are not part of the basic group health insurance plan." The Court determined that the health reimbursement benefits were supplemental and not part of the District's health insurance plan, so they were not covered under PSEBA.
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