Donna Carpenter's article "Risky Business" (Financial Tactics, January) was a balanced presentation of both sides of self-insurance. I would suggest one clarification, however. You mention that self-insured employers can pay medical bills that the insurance carriers occasionally refuse to cover, giving two examples in which the employer chooses to reimburse employees for medical and dental expenses that would not have been covered under the insurance contract.

An employer is free to reimburse for these expenses as long as it does so on a nondiscriminatory basis -- that is, if you do it for one employee, you must do it for all. Since, as you correctly point out later in the article, the employer is the sole responsible fiduciary, to refuse a payment for a service that has been covered before opens the employer to a charge of discrimination from the employee who had his claim denied. This is the main reason why employers are careful about paying claims for services that are outside of the contractual obligated coverages.