Short answer: No. Insurance that pays only for accidental death is not group term life for the $50,000 rule, so AD&D is not added to the life amount when figuring imputed income. Accident-only coverage, including AD&D, is also an excepted benefit outside the health plan’s HIPAA and ACA rules.
The IRS excludes from group term life any insurance that does not provide a general death benefit, and names a policy providing only accidental death benefits as an example. So when a plan pairs $100,000 of basic life with $100,000 of AD&D, only the $100,000 of life is compared with $50,000.
Employer contributions to accident or health coverage, including payments for specific permanent injuries such as the loss of use of an arm or leg, are generally excluded from wages under the accident and health rules.
On the compliance side, the federal portability and market reform rules list coverage only for accident, including accidental death and dismemberment, as an excepted benefit in all circumstances. AD&D sits outside those group health plan requirements, though an employer subject to ERISA still treats it as a welfare benefit.