What does the salary sacrifice consultation tell us about the state of the group risk industry?

336 responses were made to the consultation and the outcome was that Excepted Group Life and Group Income Protection (GIP) were to be treated as P11d benefits in kind, and confirmation that Partners' Life Assurance and Group Critical Illness were maintained as P11d benefits.  Could we have done better, specifically on GIP, and what does this tell us about the group risk industry? I have no idea what initial evidence gathering was undertaken by HMRC (it seemed to be employer and not industry-focused).  I only got involved when the consultation itself was launched, which was already ...