Regulators Reiterate Ban on Third-Party "Special Drug Cards" as "Insurance+" Boundaries Need Clarification

Deep News03-18

Offering additional value-added services has become a key method for customer acquisition in the insurance industry. However, providing policyholders or insured individuals with benefits outside the contract remains strictly prohibited.

Recently, the Hubei Regulatory Bureau of the National Financial Regulatory Administration issued a notice to Changjiang Property & Casualty Insurance, Union Life Insurance, Guomin Life Insurance, and other provincial branches of insurance companies within its jurisdiction. The notice requires the standardization of insurance business practices, specifically prohibiting the provision of benefits outside the contract, such as "special drug cards" or similar entitlement cards. It explicitly bans the improper gifting of "special drug cards," "CAR-T cards," and other such entitlements to insurance consumers.

This is not the first time regulators have addressed this issue. As early as November 2024, the Henan Regulatory Bureau of the National Financial Regulatory Administration issued a similar notice to life insurance branches within its jurisdiction, explicitly prohibiting such practices.

As a vital tool for risk management, insurance is intended to provide consumers with peace of mind and protection. However, due to sales pressures, such "rebate" practices can disrupt normal market order and create potential disputes in future claims services.

**Strict Prohibition on Gifting**

The Hubei Bureau stated that recent regulatory inspections have revealed some insurance companies gifting "special drug cards" and similar entitlements to consumers during business activities, which constitutes providing benefits outside the insurance contract. To maintain market order and prevent operational and compliance risks, the bureau has made it clear that gifting such cards is strictly forbidden.

In fact, this is not the first regulatory warning on the matter. In November 2024, the Henan Bureau issued a notice banning the provision of benefits outside the contract through "special drug cards" or "CAR-T cards," while encouraging insurers to explore differentiated operations and appropriately offer value-added services that meet consumer needs. During the "3·15" consumer rights period in 2025, a Guangdong "3·15" gala also exposed the trap of offering special drug cards as incentives for purchasing insurance.

Beyond rectifying market order, the primary reason for the regulatory crackdown is to prevent greater risks.

It is understood that providers of "special drug cards" and "CAR-T cards" are third-party institutions. These entities are often small, financially weak, and lack qualifications to operate financial businesses. Their products mimic the terms and coverage of insurance policies, which can easily lead to disputes among consumers, third-party providers, and insurance companies.

For example, a customer might purchase insurance specifically to obtain such a card. However, if the service is needed later, the third-party provider—lacking financial business qualifications—may no longer exist or fail to deliver the promised service. The consumer would then likely turn to the insurance company, but since the service is not part of the insurance coverage, this can easily trigger three-way disputes. Additionally, it can blur the line between third-party entitlements and insurance benefits, prompting regulators to intensify efforts against such violations.

**Uncovering the Issues**

Special drugs and CAR-T therapies are treatments for major diseases.

Special drugs refer to medications for serious illnesses, including but not limited to cancer treatments, drugs for rare diseases, hematopoietic stem cell transplantation drugs, and gene therapies. These drugs are characterized by their precise efficacy and lack of alternative treatments. They are often highly effective but expensive. While some regions include them in medical insurance reimbursement schemes, others require patients to pay out-of-pocket.

CAR-T, or chimeric antigen receptor T-cell immunotherapy, is a novel precision-targeted therapy for tumors. Through recent optimizations, it has shown significant clinical success, offering a promising, precise, and potentially curative approach to cancer treatment. However, CAR-T therapy is extremely costly.

Changes in social environments, lifestyles, and an aging population have led to rising rates of major diseases in China. Conditions like cancer and cardiovascular diseases not only threaten lives but also impose heavy financial burdens on families. Statistics indicate that the average cost of treating a major illness can reach hundreds of thousands of yuan, excluding follow-up rehabilitation expenses—a sum often unaffordable for ordinary households. This reality drives high demand for special drugs and CAR-T therapies.

Within the insurance industry, value-added services like special drug benefits originated in life insurance, serving as a "door opener" for agents to attract customers, especially during peak sales periods. Aggressive promotion by pharmaceutical companies has also contributed to the widespread adoption of such services in the industry.

An industry insider noted that while these services attract customers, they pose significant risks for insurers. "Once a claim involving special drugs is triggered, the insurer is certain to incur losses. Consequently, such coverage has largely been removed from long-term insurance products. It may still appear in some one-year policies, but the risks for insurers are much lower."

Currently, besides the clearly illegal practice of gifting "special drug cards," there is a legitimate approach: incorporating special drug coverage or CAR-T therapy into the insurance policy itself, such as in short-term critical illness insurance, million-yuan medical policies, or inclusive health insurance plans.

**Clarifying Boundaries**

In competitive markets, offering promotional gifts or incentives to valued or long-term customers is a common sales tactic across industries, aimed at enhancing customer experience. For insurers, improving value-added services is a key strategy for acquiring and retaining customers.

The "Health Insurance Management Measures" state that health management services can be specified in the insurance policy or agreed upon in a separate contract. The "Notice on Regulating Health Insurance Companies' Health Management Services" further clarifies that standalone health management services require a separate contract detailing the services and their costs, and insurers must provide these services in a standardized manner.

There is nothing wrong with insurers offering value-added services, especially when they enhance customer loyalty and satisfaction. However, using expensive entitlement cards as gimmicks can lead to disputes if third-party providers fail to meet customer expectations.

To address this, the Hubei Bureau requires insurers to strictly adhere to regulations, standardize business practices, and strengthen agent management. They must not gift entitlement cards, procure or distribute such cards for sales or customer retention purposes, imply that the cards are provided by the insurer, or conflate card benefits with insurance coverage, thereby misleading consumers.

Simultaneously, regulators encourage compliant value-added services. This includes tailoring services to different customer segments, clearly distinguishing between legitimate value-added services and illegal benefits outside the contract, and offering scientifically sound health management services based on the company's capabilities and customer needs.

The Hubei Bureau has instructed insurers to conduct immediate self-inspections, identify any practices involving the gifting of "special drug cards" or similar benefits outside the contract, and cease such activities promptly. They must also resolve existing disputes and mitigate potential risks.

Ultimately, eliminating marketing misconduct requires addressing the root causes. Regulators emphasize that insurers must strengthen internal controls, ensure compliance training, and strictly manage personnel and channels to prevent the procurement and use of such entitlement cards in insurance activities.

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