Currently, there exists a severe inequity in Treasury regulations in the way stand-alone vision plans (SAVPs) are treated under the Affordable Care Act (ACA). Section 9010 of the ACA imposes a health insurer fee on covered entities engaged in the business
of providing health insurance. While it can be debated whether or not the fee ever made sense for a traditional health insurance company, it is clear that this fee should never have applied to SAVPs.