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Supplemental Life Insurance

Supplemental life insurance is the extra coverage an employee buys and pays for through a workplace group plan, on top of whatever the employer provides. It is employee-paid, but that alone does not keep it out of the tax rule that applies to employer-provided coverage.

Last reviewed by Steven Fox, CFP®, EA on

Quick Summary

  • It is the layer you pay for inside the employer's group plan, usually sold as additional multiples of salary alongside a small employer-paid base amount.
  • Paying for it yourself does not automatically put it outside section 79. A plan is treated as carried by the employer if it charges some employees less than the IRS table cost and others more, even where the employer pays nothing.
  • There is normally a guaranteed issue amount you can elect with no health questions, and evidence of insurability is required above it or if you enroll late.
  • Group pricing is banded by age and averaged across the workforce, so it is a bargain for someone in poor health and often not one for a young non-smoker.
  • Like the base coverage, it generally ends with the job. Portability and conversion are separate rights that may or may not be offered.

Definition

Supplemental life insurance, also sold as voluntary life insurance, is additional group life coverage offered through an employer's plan and paid for by the employee, usually through payroll deduction. The employer arranges and sponsors it; the employee elects the amount and bears the cost. It sits on top of the basic employer-paid coverage most plans provide, and it is typically offered in multiples of salary or in fixed increments, sometimes with matching options for a spouse or child.

The word supplemental describes the layer, not a different kind of insurance. The underlying contract is the same group term life insurance the base coverage comes from, issued under one master policy with each employee holding a certificate. What changes is who pays, and, in a way that surprises most people who look at it, whether that is enough to change the tax treatment.

Advanced Explanation

Employee-paid does not mean outside the tax rule, and the regulation says why in one sentence. Section 79(a) of the tax code includes in an employee's income the cost of group-term life insurance "carried directly or indirectly by his employer," to the extent that cost exceeds the sum of the cost of $50,000 of such insurance and the amount the employee paid toward it. The definition of what is carried by the employer sits in 26 CFR 1.79-0, and it has two limbs. The first is obvious: the employer pays part of the cost, directly or through another person. The second is not. A policy is also carried by the employer if the employer "or two or more employers arrange for payment of the cost of the life insurance by their employees and charge at least one employee less than the cost of his or her insurance, as determined under Table I of section 1.79-3(d)(2), and at least one other employee more than the cost of his or her insurance, determined in the same way."

That second limb is the mechanism behind the whole page, and practitioners call it the straddle. A voluntary plan almost always charges by age band, and the IRS table is also banded by age but with its own rates. Wherever the plan's rate for one band sits below the table rate and another band's sits above it, the plan straddles the table, and the employer is treated as carrying the coverage even though it contributes nothing. The consequence is that supplemental amounts are then folded into the section 79 calculation with the base coverage: the same $50,000 exclusion applies once across the whole group-term total, the imputed cost comes from the IRS table rather than from what anyone actually paid, and what the employee paid is subtracted from that figure. Published material on employer coverage rarely mentions this, which is why an employee occasionally sees imputed income on a plan they were told they were paying for themselves.

The guaranteed issue amount is the other thing worth knowing before open enrollment closes. Voluntary plans normally let an employee elect up to a stated amount with no health questions during an initial eligibility window, and require evidence of insurability above it, for later increases, or for anyone enrolling after their first opportunity. The window is the valuable part: an employee who takes the coverage when first offered gets it without underwriting, and one who waits usually does not. That matters most for exactly the people who benefit most from group coverage, since a health change between the first offer and the later election is what makes the underwriting bite.

Whether to take it, stated as a comparison rather than a rule. Group rates are set for the workforce as a whole and banded broadly, while an individually underwritten term policy is priced on one person's age, health and tobacco use. For someone young, healthy and a non-smoker, an individual policy frequently costs less per dollar of coverage than the supplemental layer, and it does not end when the job does. For someone whose health would produce a rated offer or a decline, the supplemental layer up to the guaranteed issue amount is often the cheapest coverage available anywhere and is worth taking to the limit. The question is not which product is better but which side of that line the particular employee is on, and the way to answer it is to price an individual policy for the same face amount and compare.

The exit is the recurring disappointment. Supplemental coverage ends with employment unless the plan offers portability, which continues the group term coverage for a period, or conversion, which turns it into an individual permanent policy without new medical evidence and at a substantially higher premium. A plan may offer one, both or neither, and both are normally available only for a short window after coverage ends. That is the fact to establish before relying on the coverage for a need that outlasts the job.

Used in a Sentence

“Yusuf elected three times salary in supplemental life insurance during his first week, because after that window the plan would have required medical evidence for any amount above one times salary.”

How It Works

At hire or at open enrollment the employee is offered coverage in stated increments, elects an amount, and the premium is deducted from pay. Elections up to the plan's guaranteed issue amount are accepted without health questions; above it the insurer sends a health questionnaire and may require more. The employee names a beneficiary, and that designation controls who is paid. Rates are set by age band and are re-rated as the employee crosses into a new band, which is why the deduction rises every few years without the coverage changing.

A hypothetical, to show how the straddle rule reaches coverage nobody's employer paid for. Suppose a plan charges every participant $0.09 per $1,000 of coverage per month regardless of age. The IRS table in 26 CFR 1.79-3(d)(2) sets its own monthly rate per $1,000 by five-year age bracket, and those rates rise steeply with age. A 30-year-old is therefore being charged more than the table cost of their insurance, and a 60-year-old less. Under 26 CFR 1.79-0 that is precisely the second limb: at least one employee charged less than the table cost and at least one charged more. The plan is carried by the employer, and every participant's coverage above the section 79 threshold enters the imputed income calculation. The rate here is invented; the point is that a single flat rate across all ages is enough on its own to create the straddle.

The practical follow-through is short. Look at the plan's rate sheet: if it is banded by age in a way that tracks the IRS table closely, the plan may avoid the straddle, and if it is flat or banded coarsely it almost certainly does not. Then look at a recent pay stub or Form W-2 for imputed income on group-term life, which is where the answer actually shows up.

Pros and Cons

Pros

  • Coverage up to the guaranteed issue amount is available with no health questions during the initial window, which is the cheapest coverage available to anyone with a health history.
  • Payroll deduction makes it administratively simple, and elections can usually be changed at each open enrollment.
  • Group rates can be favorable for older employees, because the pricing is averaged across a workforce.
  • Spouse and child coverage is often available through the same election.

Cons

  • Paying for it yourself does not reliably keep it out of section 79. A plan that straddles the IRS table is treated as employer-carried, so the coverage can still generate imputed income.
  • It ends when the job does, and portability and conversion are limited, time-boxed and, in the case of conversion, expensive.
  • For a young non-smoker in good health, an individually underwritten term policy frequently costs less for the same face amount and is not tied to an employer.
  • Rates step up as the employee crosses age bands, so the cost rises over a career while the coverage stays the same.
  • Electing above the guaranteed issue amount, or enrolling late, requires evidence of insurability, which can be declined.

People Also Asked

Answers to the most frequently asked questions.

If I pay for supplemental life insurance myself, is it still taxed?
Possibly, and the answer turns on how the plan's rates compare to the IRS table. Under 26 CFR 1.79-0, a policy is carried by the employer not only when the employer pays part of the cost but also when the employer arranges employee payment and charges at least one employee less than the table cost of their insurance and another more. A plan structured that way falls inside section 79, so coverage above the statutory threshold produces imputed income even though the employer contributed nothing.
Should I buy supplemental life insurance through work or my own policy?
Compare the two for the same face amount before deciding. Group rates are averaged and banded, so someone young, healthy and a non-smoker will often find an individually underwritten term policy cheaper, and it stays with them when they change jobs. Someone whose health would draw a rated offer or a decline usually finds the workplace coverage up to the guaranteed issue amount is the best available, and worth electing to the limit.
What is a guaranteed issue amount?
It is the amount of coverage a group plan will issue without asking health questions, available during a stated enrollment window. Elections above it, increases made later, and enrollment after the first opportunity generally require evidence of insurability, meaning a health questionnaire and sometimes more, which the insurer can decline. Taking the coverage when it is first offered is what preserves the no-questions route.
Can I keep supplemental life insurance if I leave my job?
Only if the plan offers portability or conversion, and only inside a short window after coverage ends. Portability continues the group term coverage for a period; conversion exchanges it for an individual permanent policy without new medical evidence but at a substantially higher premium. A plan may offer one, both or neither, so it is worth confirming which applies before treating the coverage as long-term.

Sources

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  1. U.S. Code. "26 U.S.C. § 79 — Group-term life insurance purchased for employees."
  2. Code of Federal Regulations. "26 CFR 1.79-0 — Group-term life insurance—definitions of certain terms."
  3. Code of Federal Regulations. "26 CFR 1.79-3 — Determination of amount equal to cost of group-term life insurance."

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