Yes, they are. I wrote in about an example and received that response directly from Hhonors last year.

Sort of related, I was contacted by someone claiming to be forming a class action with their chief issue being advertising based, where the advertised benefit (category x) rates never being available in cases like this. I declined to participate. I have never heard anything else about it. I made no legal judgement but really detest those types of legal actions as making things worse for the program in general. People who believe everything can be made to be fair to all in all circumstances never seem to get that they are lowering the benefit to all, well nevermind, as that's another topic entirely.